Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 2/2/2015 10:21:00 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00514-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 2/2/2015 10:21:00 AM CHRISTOPHER PRINE CLERK
NO. 14-14-00514-CR
PAUL WAYNE HARRIS § IN THE COURT OF APPEALS
VS. § FOURTEENTH JUDICIAL DISTRICT
STATE OF TEXAS § HOUSTON, TEXAS
STATE’S FIRST MOTION FOR EXTENSION OF TIME
TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF
APPEALS:
Pursuant to Texas Rule of Appellate Procedure 38.6(d), the State, by and
through its Fort Bend County District Attorney, asks this Court to grant an extension
of time to submit its appellate brief in the above-referenced cause.
Pursuant to Texas Rule of Appellate Procedure 10.5(b), the State provides the
following information:
Current Deadline: February 2, 2015
Length of Extension Sought: 60 days to April 3, 2015
Number of Previous Extensions: None
Facts reasonably explaining the need for an extension:
In the last thirty days, the undersigned assistant district attorney completed the
State’s response to the petition for writs of mandamus and prohibition in Ex rel James
Albert Turner v. Brady G. Elliott, Judge 268th District Court, No. WR-80,559-02
(leave to file denied January 26, 2015); the State’s petition for discretionary review
in Moore v. State , No. PD-1634-14; and assisted and continues to assist in the
preparation for a retrospective competency jury trial in a death penalty case, State of
Texas v. Albert James Turner , Cause No. 10-DCR-054233, set for February 3, 2015.
The undersigned has been assigned to write the State’s appellate brief in Gamez
v. State , No. 14-14-00203-CR, due March 8, 2015, on an extended deadline, and the
State’s supplemental answer in Ex parte Sandbloom , WR-79,922-02, issues to be
resolved before March 10, 2015, on remand by the Court of Criminal Appeals.
The undersigned is one of three appellate attorneys assisting forty-nine trial and
administrative attorneys with research and trial support.
The State asks for an extension of time not for delay only, but to see that justice
is done. Barring unforeseen circumstances, the State will not seek any further
extension of time.
Respectfully submitted,
John F. Healey, Jr. SBOT # 09328300
District Attorney, 268th Judicial District
Fort Bend County, Texas
/s/ Gail Kikawa McConnell
Gail Kikawa McConnell
SBOT # 11395400
Assistant District Attorney
301 Jackson Street, Room 101
Fort Bend County, Texas 77469
(281) 238-3205/(281) 238-3340 (fax)
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing State's motion for extension of time
was served on February 2, 2015, on Mr. David Alan Disher, Attorney for Appellant
through the electronic filing manager or by email.
/s/ Gail Kikawa McConnell
Gail Kikawa McConnell