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No. PD-1537-15, PD-1538-15, PD-153P-15, PD-1540-15, PD-1541-15 ABEL ACOSTA y/ L/ S ' • ' J CLERK

TO THE COURT OF CRIMINAL APPEALS

FILED IN

COURT OF CRIMINALAPPEALS

From the First Court of Appeals

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 of Texas

Appellant's Final Motion To Extend Time

To File Petition For Discretionary Review

For Five Days, Accompanied by PDR

To The HonorableJudges Of The Court Of Criminal Appeals:

Comes Now, Hugo Pachas-Luna, and files this his Final 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 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

Domingo Medina, 01-15-00575-CR

Kori Henegar, 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 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 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 correct copy ofthe 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