Roach, Chance

• Court: Court of Appeals of Texas
• Decided: May 28, 2015
• Docket: PD-0643-15
• Status: Published

Opinion

PD-0643-15 PD-0643-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS May 28, 2015 Transmitted 5/27/2015 6:37:48 PM Accepted 5/28/2015 4:20:08 PM TO THE COURT OF CRIMINAL APPEALS ABEL ACOSTA CLERK

FROM THE FIRST COURT OF APPEALS NO. 01–14–00392–CR

CHANCE ROACH APPELLANT On Appeal from Cause Number 1394753 From the 185th District Court of Harris County

V.

THE STATE OF TEXAS APPELLEE

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

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:

COMES NOW, CHANCE ROACH, and files this his Motion to Extend Time to File Petition for Discretionary Review, and in support thereof, would respectfully show the Court the following:

I. The First Court of Appeals affirmed the trial court’s judgment in Roach v. State, 01-14-00392- CR, 2015 WL 1778896 (Tex. App.—Houston [1st Dist.] Apr. 16, 2015, no. pet. h.). No motion for rehearing was filed. No other motions for extension have been filed.

II. In compliance with Texas Rule of Appellate Procedure 68.2(c), this motion for extension is timely filed within 15 days of the original deadline for the PDR, which was May 18, 2015. Appellant requests this extension due to the fact that counsel for Appellant has been engaged in work in the Harris County Public Defender’s Office on many cases, including the following:

 Rodney Robins, 01-14-00582-CR  Stephen Hopper, 14-15-00371-CR  Pete Rodriguez, 14-15-00339-CR  Vincent Williams, 14-15-00220-CR  Darryle Robertson, 14-15-00132-CR  Leonard Storemski, 14-14-00921-CR  Counsel has been researching and writing for several trial cases assigned to the Public Defender’s Office Trial Division. III. Appellant’s attorney requests this brief extension which is necessary so that the petition can be thoroughly written and timely filed. This motion is not made for the purpose of delay.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court grants this requested extension of time to file the appellant’s petition for discretionary review in the above cause and extend the time for filing for 30 days, to June 27, 2015.

Respectfully submitted,

ALEXANDER BUNIN Chief Public Defender Harris County, Texas

/s/Sarah V. Wood SARAH V. WOOD Assistant Public Defender Harris County, Texas Texas Bar Number 24048898 1201 Franklin, 13th Floor Houston Texas 77002 713.368.0016 (phone) 713.368.9278 (fax) Sarah.Wood@pdo.hctx.net

Attorney for Appellant

CERTIFICATE OF SERVICE

By my signature below, I hereby certify that a true and correct copy of the above and foregoing Appellant’s Motion to Extend Time to File Petition for Discretionary Review has been served on the District Attorney of Harris County, Texas, by electronic delivery through the efile system.

/s/Sarah V. Wood Sarah V. Wood Attorney for Appellant