0101-15 FILED IN COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 7/6/2015 12:00:00 AM July 6, 2015 IN THE Accepted 7/6/2015 8:07:10 AM ABEL ACOSTA TEXAS COURT OF CLERK ABELACOSTA, CLERK CRIMINAL APPEALS

OSMIN PERAZA

VS. § Case Numbers 0100-15 & 0101-15 THE STATE OF TEXAS i «?&* ** Ot Motion to Extend Time to File Motion for Rehearing i ^ Now comes Osmin Peraza, appellant in the above-styled and numbered causes, by and through assistant public defender, Jani J. Maselli Wood, and respectfully moves the Court for an extension of time within which to file his motion for

rehearing, and for cause would show the Court as follows: I.

On July 1, 2015, this Court issued its opinions in the above-referenced case.

The cases reversed the lower court of appeals.

II.

The motion for rehearing is currently due July 16, 2015.

III.

Undersigned counsel is requesting 7 days from the current due date until July 23, 2015.

IV.

Undersigned counsel has numerous deadlines in the next thirty days and has been working diligently to handle all her cases: PDR's due (NFE because of previous extensions) Gregorio Guerrero v. State, due 7/15/2015; Kenneth McAfee v. State, due 7/13/2015 Briefs due:

Brief after PDR granted due in Joshua London v. State, due July 24, 2015 Shaun Briggs v. State, 01-15-00269-CR - due July 15, 2015 CarlLovings v. State, 14-15-00167-CR - due on July 19, 2015 Mario Dunn v. State, 14-15-00340-CR - due on July 27, 2015 CLE

Counsel is the course director and will be attending Train the Trainers and a CDLP training in South Padre Island from July 7-11, 2015.

V.

This request is made not to delay the proceedings, but to ensure that Mr. Peraza is adequately represented.

WHEREFORE, PREMISES CONSIDERED, Mr. Peraza respectfully prays that this the Court permit an extension of time until July 23, 2015.

Respectfully submitted, ALEXANDER BUNIN Chief Public Defender Harris County Texas Isi JaniMaselli Wood JANI J. MASELLI WOOD Assistant Public Defender State Bar Number 00791195 Harris County Texas 1201 Franklin, 13th Floor Houston Texas 77002 (713) 368-0001 (713) 368-9278 (Fax) [email protected] Attorney for Appellant, Osmin Peraza

CERTIFICATE OF SERVICE

Pursuant to Tex. R. App. Proc. 9.5, this certifies that on July 2, 2015, a copy of the foregoing was emailed to counsel for the state (through texfile.com) at the following address: Lisa McMinn [email protected] Isi JaniJMaselli Wood JANI J. MASELLI WOOD