Case Information

*1 PD-1341-14 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 4/24/2015 2:13:36 PM Accepted 4/24/2015 2:28:16 PM ABEL ACOSTA IN THE CLERK COURT OF COURT OF CRIMINAL APPEALS OF TEXAS ______________________________

No. PD-1341-14

_______________________________

STACY STINE CARY, Appellant

THE STATE OF TEXAS, Appellee __________________________________________________________________

On Appeal from the Court of Appeals, Fifth District of Texas at Dallas

Court of Appeals No. 05-12-01421-CR __________________________________________________________________

APPELLANT'S UNOPPOSED FIRST MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

Appellant Stacy Stine Cary respectfully moves for an extension of time to file her Appellant’s Brief by thirty (30) days. In support of this motion, she would respectfully show as follows:

1. The deadline for filing the Appellant’s Brief is April 24, 2015.

2. Appellant seeks a thirty-day extension.

3. An extension is necessary because of appellate counsel’s schedule since the time the PDR was granted, the complexity of the facts and issues, and the fact that the Fifth Court of Appeals has now issued an opinion in the related case of David Cary v. State of Texas , No. 05-13-01010-CR, in which the Court of Appeals *2 reversed the appellant’s conviction, and this opinion should be addressed in the initial brief. APPELLEE, THE STATE OF TEXAS, DOES NOT OPPOSE THIS REQUESTED EXTENSION.

4. No previous extension has been sought or granted.

Respectfully submitted, ____/s/ John M. Helms____________ John M. Helms

Texas Bar No. 09401001 BRODEN, MICKELSEN, HELMS & SNIPES, LLP

2600 State Street Dallas, Tx 75204 Tel: (469) 951-8496 Fax: (214) 720-9594 john@johnhelmslaw.com ATTORNEY FOR APPELLANT, STACY STINE CARY CERTIFICATE OF CONFERENCE

Undersigned counsel has conferred with Joseph Corcoran, counsel for Appellee, the State of Texas, and the Appellee does not oppose this motion.

CERTIFICATE OF SERVICE

This certifies that a true and correct copy of this instrument has been served on counsel of record on April 23, 2015, as follows:

Joseph Corcoran

Assistant Attorney General

P.O. Box 12548

Capitol Station

Austin, TX 78711

* DELIVERED VIA E-MAIL *