Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 3/23/2015 8:56:46 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-13-00778-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 3/23/2015 8:56:46 AM CHRISTOPHER PRINE CLERK No. 01-13-00778-CR In the

Court of Appeals

For the First District of Texas At Houston ♦

No 1380317

st In the 351 District Court Of Harris County, Texas ♦ DANIEL GONZALEZ RODRIGUEZ 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 charged by indictment with kidnapping. (CR 21).

The indictment alleged two prior felony convictions, with one offense

committed after the other conviction became final. (CR 21). A jury

found him guilty as charged. (CR 50, 51). The appellant pled true to

both enhancement paragraphs and the trial court assessed

punishment at thirty years’ confinement. (CR 50). The appellant filed

a timely notice of appeal and the trial court certified his right of appeal. (CR 55, 58).

2.

The State’s brief is due on March 23, 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 March

4, 2015. Since that time, he has worked on the following

mattters:

1. Craig Gilder

No. 14-14-00523-CR

Brief filed March 6, 2015

2. Julio Alvarado

Nos. 01-13-00894-CR & 01-13-00895-CR

Brief filed March 19, 2015

et seq.

3. Hugo Pachas-Luna

Nos. 01-14-00516-CR

Brief due March 23, 2015 (third motion for extension filed)

b.

The undersigned attorney was out of the office for a medical

procedure on March 20, 2015.

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) 755-5826 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:

Kurt B. Wentz

kbsawentz@yahoo.com

C LINTON A. M ORGAN /s/ C.A. Morgan Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 (713) 755-5826 morgan_clinton@dao.hctx.net TBC No. 24071454 Date: March 23, 2015