Ibarra, Jamie Alberto

Opinion

PD-0206-15

COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 3/24/2015 10:06:58 AM Accepted 3/25/2015 2:41:58 PM PD-0206-15 ABELAJP|TA CLERK

JAMIE ALBERTO IBARRA X IN THE COURT OF CRIMINAL APPEALS

X

vs. x ^X^+° x 4^1* THE STATE OF TEXAS x X OF THE STATE OF TEXAS SV ^L_

MOTION FOR ONE-WEEK EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

COMES NOW, JAMIE ALBERTO IBARRA, Appellant, and moves for an extension of seven (7) days in which to file his Petition for Discretionary Review, until and including April 1, 2015, and would further show as follows: A. On January 22, 2015, in cause number 14-13-00337-CR, styled 'Jamie Alberto Ibarra vs. The State of Texas," the Fourteenth Court of Appeals affirmed the Appellant's conviction for aggravated assault on a public servant. No motion for rehearing was filed.

B. The deadline for filing the Petition for Discretionary Review in this cause is currently Wednesday, March 23, 2015.

C. A request is hereby made for an extension of time to file the Appellant's Brief, until and including April 1, 2015.

D. The undersigned attorney, Bob Wicoff, has been unusually busy with other matters which have kept him from completing the PDR by the current

deadline, including, but notlimited to, the following: C0URT OF CRIMINALAPPEALS March 25, 2015

ABEL ACOSTA, CLERK

FEANYICHI UVUKANSI VS. THE STATE OF TEXAS; No. 01-14-00527-

CR; Appellant's brief filed March 9, 2015 (capital murder-56-page brief);

GRISELDA AZA VS. THE STATE OF TEXAS; Nos. 14-14-00241 -CR and 14_14_00242-CR; Appellant's brief filed March 11, 2015;

RICHARD ANTHONY SCOTT VS. THE STATE OF TEXAS; No. 14-14-

00726-CR; Appellant's brief filed March 18, 2015, 2015;

NORMA SANCHEZ VS. THE STATE OF TEXAS; No. 01-14-00978-CR;

Appellant's brief filed March 19, 2015;

Additionally, the undersigned serves on the Texas Forensic Science Commission Hair Microscopy Panel, as part of a team reviewing hundreds of cases involving possible errors in expert testimony. The Panel meets this Friday, March 27, 2015, at the Texas Department of Public Safety headquarters in Austin, and in preparation for such meeting, the undersigned must complete a survey of hundreds of old homicide and murder cases to determine the status of such convictions. This

project takes a lot of time.

Finally, the undersigned also has ongoing administrative duties in his position as chief of the appellate division of the Harris County Public Defender's Office.

D. One previous extension has been granted. No further extensions will be needed.

Respectfully submitted,

ALEXANDER BUNIN

Chief Public Defender

Harris County Texas

/s/ Bob Wicoff

BOB WICOFF

1201 Franklin, Thirteenth Floor Houston Texas 77002

(713) 274-6781

TBA No. 21422700

Bob.wicoff@pdo.hctx.net

CERTIFICATE OF SERVICE

A true copy of this motion has been served electronically on the Harris County District Attorney's Office Appellate Division on the 24th day of March, 2015.

/s/ Bob Wicoff

BOB WICOFF