Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 11/4/2015 4:39:10 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00268-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 11/4/2015 4:39:10 PM CHRISTOPHER PRINE CLERK No. 01-15-00268-CR In the
Court of Appeals
For the First District of Texas At Houston ♦
No. 1450059
th In the 177 District Court Of Harris County, Texas ♦ TONI TAVAREZ
Appellant THE STATE OF TEXAS v. Appellee
♦ STATE’S FIRST MOTION FOR EXTENSION ♦
OF TIME TO FILE BRIEF
To the Honorable Court of Appeals:
The State of Texas, pursuant to T EX . R. A PP . P. 2 & 10.5, moves for an
extension of time in which to file its appellate brief. The following facts are
relevant: 1.
The appellant was indicted for murder. (CR 8). The appellant pleaded
not guilty, but a jury found her guilty as charged. (CR 329, 340). The
jury assessed punishment at fifty years’ confinement. (CR 339, 340).
The trial court certified the appellant’s right of appeal, and the appellant filed a timely notice of appeal. (CR 313, 343).
2.
The State’s brief is due on November 4, 2015. The State requests a 30-day extension of time in which to file its brief.
3. This is the State’s first request for extension.
4.
The following facts are relied upon to show good cause for an
extension of time to allow the State to file its brief: a.
This case was assigned to the undersigned attorney on October
14, 2015. Since then, the undersigned attorney has worked on
the following matters: Ex parte
1. Hugo Steve Ramirez
No. 14-15-00323-CR
Brief filed October 21, 2015
2. Marcus Jamez Lewis
No. 14-14-00779-CR
Oral argument held October 28, 2015
3. Judist Broussard
No. 01-15-0074-CR
Brief filed October 30, 2015
4. Stuart Adam Latham
No. 01-15-00139-CR
Brief filed November 3, 2015
5. Christopher Dewa Washington
No. 01-14-00366-CR
Oral argument held November 4, 2015
b.
On October 19, 2015, the undersigned attorney took the
examination for board certification in criminal appellate law.
Preparation for this exam consumed considerable time on
nights and weekends, preventing the undersigned attorney
from putting in extra time on pending briefs.
WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted, C LINTON A. M ORGAN /s/ C.A. Morgan Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 713.274.5826 morgan_clinton@dao.hctx.net TBC No. 24071454 *4 CERTIFICATE OF SERVICE I certify that I have requested that efile.txcourts.gov electronically serve
a copy of this motion to:
Daucie Schindler
daucie.schindler@pdo.hctx.net
C LINTON A. M ORGAN /s/ C.A. Morgan Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 713.274.5826 morgan_clinton@dao.hctx.net TBC No. 24071454 Date: November 4, 2015