Mary Kuol v. State

Opinion

ACCEPTED 14-14-01008-cr FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 5/6/2015 12:46:35 PM CHRISTOPHER PRINE CLERK IN THE FOURTEENTH COURT OF APPEALS OF TEXAS FILED IN 14th COURT OF APPEALS MARY KUOL § HOUSTON, TEXAS § 5/6/2015 12:46:35 PM VS. § Case Number No. 14-14-01008-CR CHRISTOPHER A. PRINE § Clerk THE STATE OF TEXAS §

First Motion to Extend Time to File Brief

Now comes Mary Kuol, appellant in the above-styled and numbered cause, by

and through assistant public defender, Jani J. Maselli Wood, and respectfully moves

the Court for an extension of time within which to file the appellate brief, and for

cause would show the Court as follows:

I.

On December 8, 2014, Ms. Kuol was convicted of the offense of

prostitution and sentenced to three years imprisonment in the Texas Department of

Criminal Justice - Institutional Division. She was convicted in cause number

1314040 in the 248th District Court of Harris County, Texas, styled The State of

Texas v. Mary Kuol.

II.

The brief is currently due May 7, 2015. No extensions have been requested.

III.

Undersigned counsel is requesting 30 days from the current due date until

June 7, 2015. IV.

Counsel has been working on a murder appeal in State v. Joe Lee Bowden. The

record is lengthy;

On April 30, 2015, counsel filed a PDR in State v. Joshua London;

On March 25, 2015, the Court of Criminal Appeals granted the State’s PDR

in Osmin Peraza v. State, NOS. PD-0100 & PD-0101-15. The CCA ordered expedited

briefing (15 days per side with no extensions of time permitted). Undersigned

counsel filed the brief on April 23, 2015. The CCA then set argument for May 20,

2015. This is also requiring additional time to prepare for argument.

V.

This request is made not to delay the proceedings, but to ensure that Ms. Kuol is

adequately represented.

WHEREFORE, PREMISES CONSIDERED, Ms. Kuol respectfully prays

that this undersigned counsel be designated as the attorney of record in this cause

and that the Court permit an extension of time until June 7, 2015. Respectfully submitted,

ALEXANDER BUNIN Chief Public Defender Harris County Texas

/s/ Jani Maselli Wood _______________________ JANI J. MASELLI WOOD Assistant Public Defender State Bar Number 00791195 Harris County Texas 1201 Franklin, 13th Floor Houston Texas 77002 (713) 368-0001 (713) 368-9278 (Fax) Jani.Maselli@pdo.hctx.net

Attorney for Appellant, Mary Kuol

CERTIFICATE OF SERVICE

Pursuant to Tex. R. App. Proc. 9.5, this certifies that on May 6, 2015, a copy

of the foregoing was emailed to counsel for the state (through texfile.com) at the

following address:

Alan Curry Assistant District Attorney 1201 Franklin Street, 6th Floor Houston, TX 77002 curry_alan@dao.hctx.net

/s/ Jani J Maselli Wood ___________________________________ JANI J. MASELLI WOOD