London, Joshua

Opinion

PD-0480-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/23/2015 11:15:06 AM July 23, 2015 Accepted 7/23/2015 11:26:18 AM IN THE TEXAS COURT OF CRIMINAL APPEALS ABEL ACOSTA CLERK AUSTIN, TEXAS

JOSHUA LONDON § § VS. § CASE NO. PD 480-15 § THE STATE OF TEXAS §

MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:

NOW COMES, the appellant, Joshua London, by and through his assistant public

defender Jani J. Maselli Wood, and respectfully moves the Court to grant an extension of time

to file the brief in this case and in support would show the Court the following:

I.

The petition for discretionary for review was filed with this Court on May 1, 2015.

Review was granted on June 24, 2015.

II.

The brief is due on July 24, 2015. Counsel is requesting an additional two weeks to finish

this brief, until August 7, 2015.

III.

The request is based upon the following:

Briefs/PDR’s filed:

7/15/2015 - Brief in Shaun Briggs v. State, 01-15-00269-CR;

7/14/2013 - PDR in Gregorio Guerrero v. State, PD 0665-15, 0666-15;

7/13/2015 - PDR in Kenneth McAfee v. State, PD 0667-15; 7/2/2015 - Reply brief filed in Mary Kuol v. State, 14-14-01008-CR;

6/28/2015 - Brief filed in Marcus Lewis v. State, 14-14-00779-CR;

Motion for Rehearing Due

7/23/2015 - Motion for Rehearing to CCA in Peraza v. State, PD 0100-15, 0101-15;

IV.

This request is not made to delay the proceedings but to ensure London is effectively

represented.

WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that this

Court grant this motion and set a due date for Mr. London’s brief on August 7, 2015.

Respectfully submitted,

ALEXANDER BUNIN Chief Public Defender Harris County Texas

Jani J Maselli Wood ___________________________________ JANI J. MASELLI WOOD Assistant Public Defender State Bar No. 00791195 1201 Franklin Street, 13th Floor Houston, TX 77002 (713) 274-6721 Attorney for Appellant, Joshua London

-2- CERTIFICATE OF SERVICE

Pursuant to Tex. R. App. Proc. 9.5, this certifies that on July 23, 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:

Eric Kugler Assistant District Attorney 1201 Franklin Street, 6th Floor Houston, TX 77002 kugler_eric@dao.hctx.net

Lisa McMinn Lisa.McMinn@SPA.texas.gov

Jani Maselli Wood _________________________________ JANI J. MASELLI WOOD

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