Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 1/15/2015 10:33:27 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-14-00361-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 1/15/2015 10:33:27 AM CHRISTOPHER PRINE CLERK

IN THE COURT OF APPEALS OF TEXAS

FIRST JUDICIAL DISTRICT

BLAKE ANTHONY MONAKINO §

§

vs. § Case No. 01-14-00361-CR

§

THE STATE OF TEXAS §

MOTION TO EXTEND TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THIS COURT:

Appellant Blake Anthony Monakino, through counsel, moves the Court to

extend time to file his brief, due January 15, 2015, for the following reasons:

1. Counsel, Assistant Public Defender, Melissa Martin has been working on many

cases including, but not limited to Hayes v. State , 01-14-00623-CR, Ramos v. State , 01-14-

00381-CR; Morris v. State, 01-14-00511-CR; and a motion for new trial in a murder case,

Carter v. State, 01-14-1006-CR, as well as the instant case and has been unable to

complete the brief despite due diligence.

2. This is the first request for an extension in this case.

In view of the foregoing, Mr. Monakino asks the Court to extend the time to

file his brief for 30 days, or up to and including February 15, 2015. This request is

made in the interest of justice and effective assistance of counsel and not for

purposes of delay.

Respectfully submitted,

ALEXANDER BUNIN

Chief, Harris County Public Defender’s Office

/s/ Melissa Martin

_________________________________

MELISSA MARTIN

Assistant Public Defender

TX. Bar No. 24002532

1201 Franklin St., 13 th Fl.

Houston, TX 77002

email: melissa.martin@pdo.hctx.net

713/274-6709 Fax 713/437-4319

CERTIFICATE OF SERVICE

I certify that a copy of the foregoing motion was electronically served on the

Harris County District Attorney’s office on January 15, 2015.

s/ Melissa Martin

__________________________

Melissa Martin