Clark, Norma Jean

• Court: Court of Appeals of Texas
• Decided: February 12, 2015
• Docket: PD-0172-15
• Status: Published

Opinion

PD-0172-15 PD-0172-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 2/12/2015 11:05:05 AM Accepted 2/12/2015 1:52:41 PM TO THE COURT OF CRIMINAL APPEALS ABEL ACOSTA CLERK

No. 01-13-00373-CR

NORMA CLARK Appeal from Cause Number 1295757 From the 228th District Court Harris County vs.

THE STATE OF TEXAS

APPELLANT’S MOTION TO EXTEND TIME TO FILE PDR

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:

COMES NOW, NORMA CLARK, and files this Motion to Extend Time to File PDR, and in support thereof, would respectfully show the Court the following:

I. The First Court of Appeals affirmed the trial court’s judgment in an opinion dated January 13, 2015. Clark v. State, 01-13-00373-CR, 2015 WL 162257 (Tex. App.— Houston [1st Dist.] Jan. 13, 2015, no. pet. h.). No other motions for extension have been filed. II. Appellant requests this extension due to the fact that counsel for Appellant has been engaged in work in the Harris County Public Defender’s Office on many cases, including the following:

 In re K.C., 2012-04759J  Curtis Fournier, WR-82,102-01  Christopher Dowden, WR-82,103-01 February 12, 2015  Rodney Robins, 01-14-00582-CR  Craig Beal, 01-12-00896-CR  Abner Washington, 01-14-00885-CR  Forest Penton, 14-14-00406-CR  Felix Irizarry, 14-14-00827-CR  Dozens of writs of habeas corpus regarding the online solicitation of a minor act being declared unconstitutional  Counsel has been researching and writing for several trial cases assigned to the Public Defender’s Office Trial Division.

III. Appellee’s attorney requests an extension of 30 days, which is necessary so that the brief can be thoroughly written and timely filed. This motion is not made for the purpose of delay.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellee prays that this Honorable Court grants this requested extension of time to file the PDR in the above cause and extend the time for filing to March 14, 2015.

Respectfully submitted,

ALEXANDER BUNIN Chief Public Defender Harris County, Texas

/s/ Sarah V. Wood SARAH V. WOOD Assistant Public Defender Harris County, Texas Texas Bar Number 24048898 1201 Franklin, 13th Floor Houston Texas 77002 713.368.0016 (phone) 713.368.9278 (fax) Sarah.Wood@pdo.hctx.net CERTIFICATE OF SERVICE

By my signature below, I hereby certify that a true and correct copy of the above and foregoing Appellant’s Motion to Extend Time to File PDR has been served via the efile service on the Harris County District Attorney’s Office.

/s/ Sarah V. Wood

Sarah V. Wood