Bailey, Lajuan Cecile

Opinion

PD-1087-15

PD-1087-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 8/20/2015 8:16:41 AM August 20, 2015 Accepted 8/20/2015 2:17:02 PM NO. ______________ ABEL ACOSTA CLERK

IN THE COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS

LAJUAN CECILE BAILEY Trial Court Number Appellant 1298261 174th District Court

Harris County, Texas

V.

Court of Appeals Number

THE STATE OF TEXAS 01-12-00200-CR

MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGES OF SAID COURT:

LAJUAN CECILE BAILEY Appellant, respectfully requests that the Court grant her motion to extend time to file her petition for discretionary review. In support of said motion, Appellant would show unto the Court the following:

I.

Appellant’s conviction was initially affirmed on October 7, 2014 by a panel of the First Court of Appeals in Cause No. 01-12-00200-CR. Appellant’s Motion for En Banc Reconsideration was granted and the opinion from October 7, 2014 withdrawn. On July 23, 2015, Appellant’s conviction was affirmed in a published 5-4 opinion. Appellant’s Petition for Discretionary Review is due August 24, 2015. This is Appellant's first request for an extension to file the petitions for discretionary review.

II.

Counsel will not be able to timely file the Petition for Discretionary Review as she has been working on the following cases in the last thirty days:

1. Counsel has been working on a brief in Erick Hernandez v. State of Texas, Cause Number 14-15-00209-CR which was filed on August 19, 2015.

2. Counsel was investigating possible Motions for New Trial in State of Texas v. Jamon Walker, a non-death capital murder. The deadline for filing a Motion for New Trial was August 15, 2015.

III.

An extension of time is necessary so that the petition can be timely filed. This motion is not made for the purpose of delay.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court will grant this requested extension of time to file the Appellant's Petition for Discretionary Review in the above cause and extend the time for filing the petition for at least thirty (30) days.

Respectfully submitted,

Alexander Bunin

Chief Public Defender

/s/ Angela Cameron

Angela Cameron

State Bar No. 00788672

Harris County Public Defender’s Office 1201 Franklin 13th Floor

Houston, Texas 77002

Tel: 713-368-0016

angela.cameron@pdo.hctx.net

CERTIFICATE OF SERVICE

I certify that on the 20th day of August 2015 a copy of the foregoing instrument has been electronically served upon the State of Texas.

/s/ Angela Cameron

Angela Cameron