Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/8/2015 5:56:03 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-14-00861-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 4/8/2015 5:56:03 AM CHRISTOPHER PRINE CLERK No. 01-14-00861-CR In the Court of Appeals For the First District of Texas At Houston  No. 1388920 In the 184th District Court of  S EGISMUNDO G ONZALEZ Appellant v.

THE STATE OF TEXAS Appellee  STATE’S MOTION FOR EXTENSION OF TIME

IN WHICH TO FILE APPELLATE BRIEF  TO THE HONORABLE COURT OF APPEALS OF TEXAS:

COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.5(b)(1)

and 38.6(d) of the Texas Rules of Appellate Procedure, and files this motion for

extension of time in which to file the State’s brief in these cases, and, in support

thereof, presents the following:

1. In the 184 district court of Harris County, Texas, cause 1388920, the State of

Texas v. Segismundo Gonzalez, appellant, was convicted of theft.

2. He was assessed punishment of confinement for 17 years in the Institutional

Division of the Texas Department of Criminal Justice.

3. The State’s brief was due on April 3, 2015.

4. An extension of time in which to file the State’s brief is requested until

March 18, 2015.

5. No previous extensions have been requested by the State.

6. The facts relied upon to explain the need for this extension are:

Since appellant filed his brief, I have filed briefs in cause numbers 14-14-

00204-CR and 14-14-00777-CR. In addition to the present case, I have 3 briefs

assigned to me, am recreating exhibits for an abatement hearing in cause

number 14-13-00767-CR, and am preparing for trial on May 4 , 2015 on the

State of Texas v. Sidney Darrell in cause number 1421932. Additionally, I assist

trial court prosecutors with legal questions on a daily basis. This motion is not

sought for delay, but so that justice may be done.

WHEREFORE, the State prays that this Court will grant an extension of time

until March 9, 2015 in which to file the State’s brief in this case.

Respectfully submitted, Abbie Miles 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 TBC No. 24072240 *3 CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument has been mailed to the

appellant’s attorney at the following address on April 8, 2015:

Leah M. Borg

874 Yorkchester No. 123

Houston, TX 77079

Borg579@att.net

Abbie Miles Date: April 8, 2015