Easley, Bobby Eugene

• Court: Court of Appeals of Texas
• Decided: April 27, 2015
• Docket: PD-0468-15
• Status: Published

Opinion

PD-0468-15 PD-0468-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 4/27/2015 10:13:29 AM Accepted 4/27/2015 2:58:07 PM ABEL ACOSTA CLERK TO THE COURT OF CRIMINAL APPEALS

No. 01-14-00296-CR

BOBBY EASLEY Appeal from Cause Number 1376456 From the 184th District Court Harris County vs.

THE STATE OF TEXAS

APPELLANT’S MOTION FOR EXTENSION TO FILE PDR

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:

COMES NOW, BOBBY EASLEY, 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 styled Easley v. State, 01-14-00296-CR, 2015 WL 1263140 (Tex. App.—Houston [1st Dist.] Mar. 19, 2015, no. pet. h.) No previous motions for extension have been filed.

II. In compliance with Texas Rule of Appellate Procedure 68.2(c), this motion for extension is timely filed within 15 days of the original deadline for the PDR, which was April 20, 2015. 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:

 Lenin Lopez, 01-13-01079-CR, reversed and set for rehearing in cause #1403196  Frelin Orellana, 14-14-00701-CR  Vincent Williams, 14-15-00220-CR  Darryle Robertson, 14-15-00132-CR April 27, 2015  Pete Rodriguez, 14-15-00339-CR  Craig Beal, 01-12-00896-CR  Abner Washington, 01-14-00885-CR  Forest Penton, 14-14-00406-CR  Leonard Storemski, 14-14-00920-CR  Felix Irizarry, 14-14-00827-CR  Counsel has been researching and writing for several trial cases assigned to the Public Defender’s Office Trial Division.

III. Appellee’s attorney requests this extension of 30 days, which is necessary so that the PDR 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 May 27, 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 Final 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