Hill, Reginald Turon

• Court: Texas Supreme Court
• Decided: November 2, 2015
• Docket: PD-1260-15
• Status: Published

Opinion

PD-1260-15 PD-1260-15 COURT OF CRIMINAL APPEALS November 2, 2015 AUSTIN, TEXAS Transmitted 11/2/2015 2:22:35 PM Accepted 11/2/2015 3:47:33 PM IN THE COURT OF CRIMINAL APPEALS ABEL ACOSTA CLERK OF THE STATE OF TEXAS

PD-1260-15 REGINALD TURON HILL § Appellant § On Petition for Review of v. § No. 14-14-00376-CR § Court of Appeals § Fourteenth District of Texas THE STATE OF TEXAS § Appellee

APPELLANT’S MOTION TO EXTEND TIME TO FILE PETITION

Appellant Reginald Turon Hill for an extension of time to file his petition for

discretionary review, under TEX. R. APP. P. 10.5(b).

I. LOWER COURT PROCEEDINGS

Judgment in this case was entered on May 8, 2014. The court of appeals affirmed

on August 25, 2015. No motion for rehearing was filed.

II. PROCEEDINGS IN THIS COURT

Mr. Hill’s petition was due on October 26, 2015 after the Court granted a

previous extension. Counsel has filed the petition today, November 2, 2015.

III. REASONS FOR REQUEST

Mr. Hill’s counsel was unable to complete the petition in the last 30 days because

counsel: 1) briefed, prepared, and argued opposition to a motion for waiver of

jurisdiction hearing in juvenile court for an appellate client whose conviction was

reversed in light of Moon v. State (the hearing was today, November 2, 2015); 2) filed a brief in Margaret Renee Mayer v. State, Cause No. 14-14-01011-CR, which had been

abated; 3) filed a brief in Eric Samuel Tucker v. State, Cause No. 01-15-00274-CR; and 4)

is working to complete two other briefs in the next two weeks. In the exercise of due

diligence, counsel could not timely complete this petition.

PRAYER

Mr. Hill respectfully requests that this motion be granted and that the Court

permit an extension of time until November 2, 2015 to file his Petition for Discretionary

Review.

Respectfully submitted,

ALEXANDER BUNIN Chief Public Defender Harris County Texas

/s/ Cheri Duncan ______________________________ CHERI DUNCAN Assistant Public Defender Harris County Texas State Bar No. 06210500 1201 Franklin, 13th Floor Houston Texas 77002 (713) 368-0016 (713) 368-9278 (Fax) cheri.duncan@pdo.hctx.net

Attorney for Petitioner/Appellant, REGINALD TURON HILL

2 CERTIFICATE OF SERVICE

I certify that a copy of Appellant’s Motion to Extend Time to File Petition for Discretionary Review was served on the State of Texas by electronic delivery to the Appellate Division of the Harris County District Attorney’s Office and the State Prosecuting Attorney, on November 2, 2015. /s/ Cheri Duncan _________________________ CHERI DUNCAN