Guerrero, Gregorio

Opinion

PD-0665-15 & PD-0666-15

PD-0665&0666-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 6/1/2015 12:25:08 PM Accepted 6/1/2015 3:50:59 PM ABEL ACOSTA

IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK AUSTIN, TEXAS

GREGORIO GUERRERO § §

VS. § CASE NOS.

§

THE STATE OF TEXAS §

MOTION FOR EXTENSION OF TIME TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:

NOW COMES, the appellant, Gregorio Guerrero, by and through his attorney Jani J. Maselli Wood, and respectfully moves the Court to grant an additional thirty days to file the petitions for discretionary review and for good cause would show:

I.

Mr. Guerrero was convicted of aggravated robbery with a deadly weapon and evading arrest. In two identical unpublished opinions, his convictions were affirmed May 14, 2015 in Cause Numbers 01-13-00821-CR and 01-13-00822-CR.

II.

The petitions are due on June 13, 2015. Mr. Guerrero is requesting an additional thirty days to prepare the petition until July 13, 2013.

III.

Undersigned counsel has numerous deadlines in the next thirty days and has been working diligently to handle all her cases:

June 1, 2015

Filed Cases Brief for Joe Bowden v. State, 14-14-00955-CR filed on May 28, 2015; PDR in Joshua London v. State, PD 0480-15 filed on May 1, 2015; Oral Argument Oral argument at the CCA in Osmin Peraza v. State on May 20, 2015 Briefs due: Mary Kuol v. State, 14-14-01008-CR - due June 8, 2015 Lawrence Glover v. State, 14-15-00082-CR - due June 11, 2015 Shaun Briggs v. State, 01-15-00269-CR - due June 15, 2015 Carl Lovings v. State, 14-15-00167-CR - due on June 19, 2015 Mario Dunn v. State, 14-15-00340-CR - due on June 26, 2015 CLE Counsel will be attending Public Defender Training and the TCDLA Rusty Duncan Seminar from June 17-20, 2015 WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that this Court grant an additional 30 days to file the petition for discretionary review.

3

Respectfully submitted,

ALEXANDER BUNIN

Chief Public Defender

Harris County Texas

/s/ Jani J. Maselli Wood

___________________________________

JANI J. MASELLI WOOD

State Bar No. 00791195

1201 Franklin Street, 13th Floor Houston, TX 77002

(713) 274-6721

Attorney for Appellant,

Gregorio Guerrero

CERTIFICATE OF SERVICE

Pursuant to Tex. R. App. Proc. 9.5, this certifies that on June 1, 2015, a copy of the foregoing was emailed to Lisa McMinn, State Prosecuting Attorney, and the Harris County District Attorney’s Office through texfile.com at the following address:

Carly Dessauer Assistant District Attorney 1201 Franklin Street, 6th Floor Houston, TX 77002 Dessauer_carly@dao.hctx.net

Lisa McMinn Lisa.McMinn@SPA.texas.gov

/s/ Jani J. Maselli Wood

___________________________________

JANI J. MASELLI WOOD