Vasquez, Gustavo Andres

Opinion

PD-1157-16 PD-1157-16 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 9/26/2016 3:13:51 PM Accepted 9/26/2016 4:22:04 PM ABEL ACOSTA CLERK NO. ______________

IN THE COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS

GUSTAVO ANDRES VASQUEZ Trial Court Number Appellant 1412198 230th District Court Harris County, Texas V.

Court of Appeals Number THE STATE OF TEXAS 14-15-00380-CR

MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGES OF SAID COURT:

GUSTAVO VASQUEZ, Appellant, respectfully requests that the Court grant

his motion to extend time to file his petition for discretionary review. In support of

said motion, Appellant would show unto the Court the following:

I.

Appellant’s conviction was affirmed on August 25, 2016 by the Fourteenth

Court of Appeals in Cause No. 14-15-00380-CR. Appellant’s Petition for

Discretionary Review is due September 26, 2016. This is Appellant's first request for

an extension to file his petition for discretionary review.

September 26, 2016 II.

Counsel will not be able to file the Petition for Discretionary Review as she has

been working on the following cases in the last thirty days:

1. Counsel was in a jury trial in cause numbers 1458488 and 1458489 in the 178th District Court of Harris County from August 29, 2016 through September 7, 2016.

2. Counsel was assisting in the trial preparation in cause number 1498963 in the 208th District Court of Harris County which was in a jury trial from September 12, 2016 through September 15, 2016.

3. Counsel was assisting in the trial preparation in cause numbers 1493243, 1487387, and 1486914 in the 185th District Court of Harris County which was in a jury trial from September 12, 2016 through September 19, 2016.

4. Counsel was out with medical appointments for two days.

5. Counsel had to attend an unexpected funeral which also required being out of the office for half of a day.

VI.

An extension of time is necessary so that the petition can be timely filed. 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 and extend the time for filing the

petition for at least thirty (30) days. Respectfully submitted,

Alexander Bunin Chief Public Defender

/s/ Frances Bourliot Frances Bourliot State Bar No. 24062419 Harris County Public Defender’s Office 1201 Franklin 13th Floor Houston, Texas 77002 Tel: 713-274-6714 frances.bourliot@pdo.hctx.net

CERTIFICATE OF SERVICE

I certify that on the 26th day of September 2016 a copy of the foregoing instrument has been electronically served upon the State of Texas.

/s/ Frances Bourliot Frances Bourliot