Hill, Reginald Turon

• Court: Court of Appeals of Texas
• Decided: September 24, 2015
• Docket: PD-1260-15
• Status: Published

Opinion

PD-1260-15 PD-1260-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS September 24, 2015 Transmitted 9/24/2015 12:40:48 PM Accepted 9/24/2015 4:36:49 PM IN THE COURT OF CRIMINAL APPEALS ABEL ACOSTA CLERK OF THE STATE OF TEXAS

PD-___________________

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

PETITIONER/APPELLANT’S MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

Petitioner/Appellant Reginald Turon Hill, moves 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 is due on September 24, 2015. No previous extensions have

been requested.

III. REASONS FOR REQUEST

Since the court of appeals handed down its judgment, counsel has been working

to complete briefs in Margaret Mayer v. State, Cause No. 14-14-01011-CR, which is

subject to abatement; Herman Whitfield v. State, Cause No. 01-15-00274-CR; Eric Samuel Tucker v. State, Cause No. 01-15-00274-CR; and Bo Daniel Shafer v. State, Cause No. 14-

15-00372-CR; as well as applications for writs of habeas corpus arising from juvenile

certification issues brought to light by the Moon/Guerrero/Yado line of cases.

IV. FILING OF MOTION

In the exercise of due diligence, counsel could not complete Mr. Hill’s petition

by the deadline. This motion is not filed for purposes of delay, but so justice may be

done.

PRAYER

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

permit an extension of time until October 24, 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 2 Attorney for Petitioner/Appellant, REGINAL TURON HILL

CERTIFICATE OF SERVICE

I certify that a copy of Appellant’s Motion to Extend Time to File Petition 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, September 24, 2015. /s/ Cheri Duncan _________________________ CHERI DUNCAN