Johnson, William

Opinion

PD-1254-15

PD-1254-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 9/22/2015 7:59:36 AM Accepted 9/24/2015 2:30:19 PM ABEL ACOSTA

IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK AUSTIN, TEXAS

WILLIAM JOHNSON § §

VS. § CASE NO.

§

THE STATE OF TEXAS §

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

NOW COMES, the appellant, William Johnson, by and through his assistant public defender 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. Johnson was convicted of aggravated robbery with a deadly weapon and sentenced to eight years imprisonment. His conviction was affirmed on August 25, 2015 in an unpublished opinion in Cause Number 14-14-00475-CR.

II.

The petitions is due September 24, 2015. Mr. Johnson is requesting an additional thirty days to prepare the petition until October 24, 2015.

.

September 24, 2015

III.

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

Orlando Salinas v. State, brief on remand filled 9/7/2015;

Shaquille Ashton v. State, brief filed on 9/2/2015 Trial Setting Counsel is set for trial in Jason Harrison v. State, in the 179th district court on October 8, 2015. Pretrial conference was held September 10, 2015. New Cases Counsel has been appointed two very complicated cases in the last two weeks.

She is diligently working on a motion for new trial due on October 1, 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,

William Johnson

CERTIFICATE OF SERVICE

Pursuant to Tex. R. App. Proc. 9.5, this certifies that on September 22, 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:

Melissa Hervey Assistant District Attorney 1201 Franklin Street, 6th Floor Houston, TX 77002 Hervey_Melissa@dao.hctx.net

Lisa McMinn Lisa.McMinn@SPA.texas.gov

/s/ Jani J. Maselli Wood

___________________________________

JANI J. MASELLI WOOD