Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/2/2015 12:18:56 PM CHRISTOPHER A. PRINE Clerk
*1 ACCEPTED 01-14-00496-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 4/2/2015 12:18:56 PM CHRISTOPHER PRINE
CLERK No. 01-14-00496-CR In the Court of Appeals for the First District of Texas At Houston Cause No. 2013R-0086 In the 155 th District Court Of Austin County, Texas
PATRICK HURD, Appellant v. THE STATE OF TEXAS, Appellee SECOND MOTION FOR EXTENSION OF TIME FOR FILING APPELLEE’S BRIEF TO THE HONORABLE FIRST COURT OF APPEALS:
Assistant District Attorney Brandy Robinson, Appellee, moves the court for an extension of time for filing Appellee's brief. This is Appellee’s second request for an extension of time. The present date for filing is April 6, 2015, and Appellee requests said time be extended until May 6, 2015.
I. Appellee seeks an extension of time for the following reasons: *2 1. Appellee has had an unexpected medical complication and is not currently
in the office. 2. Appellee’s office has only four attorneys, and Appellee is responsible for all appellate matters within the office. As part of Appellee’s additional responsibilities as a misdemeanor and felony prosecutor, Appellee has represented the State on felony and misdemeanor dockets on March 3 rd , 5 th , 19 th , 24 th , and 26 th , 2015, and will be required to represent the State on felony and misdemeanor dockets on April 7 th , 16 th , 21 st , and 23 rd , 2015.
3. Appellee was first chair on the trial of State v. Holba, Continuous Sexual Abuse of a Child, 2013R-0094, from March 9, 2015, through March 12, 2015.
II.
This is the second extension requested. Appellee has contacted Appellant’s counsel, who does not oppose the extension. There has been one previous extension.
III.
Appellee moves to extend time to file Appellee's Brief until May 6, 2015. Respectfully submitted, /s/ Brandy Robinson Brandy N. Robinson Asst. Criminal District Attorney One East Main Bellville, Texas 77418 (979) 865-5933 State Bar No. 24051688
CERTIFICATE OF SERVICE
*3 I, Brandy Robinson, hereby certify that a true and correct copy of the Second Motion for Extension of Time for Filing Appellee's Brief has been served upon, Calvin Garvie, attorney for Appellant, via email at texattycg@aol.com. Date: 04/02/2015 /s/ Brandy Robinson
Brandy Robinson *4 STATE OF TEXAS $ $
COUNTY OF ATJSTIN $ BEFORE ME, the undersigned authority, on this day personally appeared Travis J. Koehn, who after being duly sworn upon her oath did depose and state: is Travis J. Koehn, and I am the employer for Brandy Robinson, the "My name for the Appellee in the foregoing entitled and numbered cause. I am attorney of record familiar with the facts and allegations contained in the foregoing Second Motion for Extension of Time for Filing Appellee's Brief, and they
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