PD-1086-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 9/23/2015 4:03:48 PM Accepted 9/24/2015 3:54:53 PM NO. PD-1086-15 ABEL ACOSTA CLERK TO THE COURT OF CRIMINAL APPEALS FROM THE FIRST COURT OF APPEALS NO. 01-11-00258-CR JEREMY THOMAS APPELLANT On Appeal from Cause Number 1284896 From the 177th District Court of Harris County V. THE STATE OF TEXAS APPELLEE Appellant’s FINAL Motion To Extend Time To File Petition For Discretionary Review Accompanied by PDR

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:

COMES NOW, JEREMY THOMAS, 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 in an published opinion. Thomas v. State, _ S.W.3d_, 1-11-00258-CR, 2015 WL 4101164 (Tex. App.—Houston [1st Dist.]). One other motion for extension has been filed.

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, which was September 8, 2015.

Appellant requests this extension due to the fact that counsel for Appellant has experienced health issues which has delayed her work schedule and her work load has been greatly increased recently due to the loss of appellate attorneys. Whereas the division began with 10 lawyers, we are now down to only six. Counsel has been engaged in work in the Harris County Public Defender’s Office on many cases, including the following:  Felix Irizarry, 14-14-00827-CR  Domingo Medina, 01-15-00575-CR September 24, 2015  Stephen Hopper, 14-15-00371-CR  Pete Rodriguez, 14-15-00339-CR  Vincent Williams, 14-15-00220-CR  Darryle Robertson, 14-15-00132-CR  Cory Nickerson, 01-15-00764-CR, et seq.  Kori Henegar, 14-15-00529-CR  Trey Foster, 14-15-00496-CR, et seq.  Frelin Orellana, 14-14-00701-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 to the day on which the PDR is simultaneously submitted or the official date it 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) [email protected] CERTIFICATE OF SERVICE By my signature below, I hereby certify that a true and correct copy of the 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