### (bKAjJ "^ PD-1537&1538&1539&1540&1541-15

,, /<zz./l tZ COURT OF CRIMINALAPPEALS 

### XT-fAJ-fO y, J AUSTIN, TEXAS sr, j,^l+*. Transmitted 12/21/20154:50:14 PM 

## ^rw^St«ss^^^AccePted 12/22/20157:51:33AM No. PD-1537-15, PD-1538-15, PD-153P-15, PD-1540-15, PD-1541-15 ABELACOSTA 

### y/ L/ S ' • ' J CLERK
TO THE COURT OF CRIMINAL APPEALS FILED IN COURT OF CRIMINALAPPEALS From the First Court ofAppeals Nos. 01-14-00516-CR, 01-14-00517-CR, 01-14-00518-CR, December22,2015 

### 01-14-00519-CR, 01-14-00520-CR abelacosta, clerk
Hugo Pachas-Luna On Appeal from Cause Numbers 1370904, 1370905,1370906, 1370907, 1370908
vs. From the 230th District Court Harris County, Texas

State ofTexas Appellant's Final Motion To Extend Time 

### To File Petition ForDiscretionary Review For Five Days, Accompaniedby PDR To TheHonorableJudges OfThe Court OfCriminalAppeals:
Comes Now, Hugo Pachas-Luna, and files this his Final Motion to Extend Time to 

### File Petition for Discretionary Review, and in supportthereof, would respectfully show the Court the following:

I. The First Court of Appeals affirmed the trial court's judgment of guilt on October 15, 

### 2015. Appellant's PDR was due on December 16, 2015. One previous extension was granted.

II. 

### In compliance with Texas Rule of Appellate Procedure 68.2(c), this motion for extension is timely filed within 15 days of the deadline for the PDR, and is filed contemporaneously with the PDR. 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. The appellate division of our office has been 

### operating with only six attorneys when we originally had ten, which has caused a 

### dramatically increased caseload. Counsel has filed 25 briefs for appellants so far this year and is struggling to clear the courts' dockets. Counsel has most recendy been working on the following:
Lenin Lope% 01-13-01079-CR,reversed and set for rehearing in cause #1403196 

### Ruben Totten, PD-0483-15 (PDR granted) Hugo Pachas-Lunas, 01-14-00516-CR, etc. Michael Davila, 01-15-00560-CR 

### Stephen Hopper, 14-15-00371-CR DomingoMedina, 01-15-00575-CR 

### KoriHenegar, 14-15-00529-CR CraigBeal, 01-12-00896-CR 

### Joseph Smith, 14-15-00625-CR EmanuelHayes, 1408364 AndrewJackson, 01-15-00994-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 thisbriefextension which is necessary so that the petition can be thoroughly written and timely filed. This motionis notmade 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 5 days, to December 21, 2015 or the day on which the accompanied petition is deemed filed. 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 Bymy signature below, I hereby certify that a true and correctcopy ofthe above and foregoing Appellant's Motion to ExtendTime 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