Umanzor, Jairo

• Court: Court of Appeals of Texas
• Decided: April 15, 2015
• Docket: PD-0403-15
• Status: Published

Opinion

PD-0403-15 COURT OF CRIMINAL APPEALS April 15, 2015 PD-0403-15 AUSTIN, TEXAS Transmitted 4/9/2015 11:01:38 AM Accepted 4/15/2015 2:46:17 PM ABEL ACOSTA IN THE COURT OF CRIMINAL APPEALS CLERK OF THE STATE OF TEXAS NO. _________

JAIRO UMANZOR Appellant, On Appeal from the V. 228TH District Court of Harris County, Texas; Trial Cause Number 1349385 THE STATE OF TEXAS

PETITIONER'S MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUSTICES OF SAID COURT:

JAIRO UMANZOR, Petitioner in the above cause number, would respectfully

request this Court to grant his motion to extend the time to file his petition for

discretionary review. In support of said motion, Mr. Umanzor would show unto the

Court the following:

I.

This appeal lies from Mr. Umanzor’s conviction in The State of Texas v. Jairo

Umanzor, Cause Number 1349385 in the 228th District Court of Harris County, Texas.

Mr. Umanzor was charged by indictment with murder. Mr. Umanzor was convicted

by a jury and sentenced by the jury to fifteen (15) years in the Institutional Division of

the Department of Criminal Justice. Mr. Umanzor’s conviction was affirmed on March 26, 2015, by the Fourteenth Court of Appeals in Cause No. 14-13-00958-CR.

Mr. Umanzor’s Petition for Discretionary Review is due April 27, 2015. This is Mr.

Umanzor’s first request for an extension to file the petition for discretionary review.

II.

Mr. Umanzor’s attorney of record, Daucie Schindler, is requesting an extension

of time in order to further evaluate the complex issues involved in the case. An

extension of time is necessary so that the petition for discretionary review can be

timely filed and undersigned counsel can properly consult with Mr. Umanzor. This

motion is not made for the purpose of delay.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this

Honorable Court will grant this requested extension of time to file the Appellant's

Petition for Discretionary Review in the above cause for thirty days and extend the

time for filing the petition until May 27, 2015. Respectfully submitted,

Alexander Bunin Chief Public Defender

/s/ Daucie Schindler Daucie Schindler State Bar No. 24013495 Harris County Public Defender’s Office Assistant Public Defender 1201 Franklin 13th Floor Houston, Texas 77002 Daucie.Schindler@pdo.hctx.net Tel: 713-368-0016 Fax: 713-368-9278

CERTIFICATE OF SERVICE

I do hereby certify that a copy of the foregoing instrument was this day electronically served on counsel for the State and by mailing same to the following parties on this the 9th day of April, 2015:

Ms. Abbie Miles Harris County District Attorney's Office Appellate Division 1201 Franklin, Suite 600 Houston, Texas 77002

State Prosecuting Attorney P.O. Box 12405 Austin, Texas 78711

/s/ Daucie Schindler Daucie Schindler