Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 5/18/2015 3:34:46 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00269-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 5/18/2015 3:34:46 PM CHRISTOPHER PRINE CLERK IN THE FIRST COURT OF APPEALS

OF TEXAS SHAUN DEVELLE BRIGGS §

§ VS. § Case Number No. 01-15-00269-CR

§ THE STATE OF TEXAS §

First Motion to Extend Time to File Brief

Now comes Shaun Develle Briggs, appellant in the above-styled and numbered

cause, by and through assistant public defender, Jani J. Maselli Wood, and

respectfully moves the Court for an extension of time within which to file the

appellate brief, and for cause would show the Court as follows:

On February 18, 2015, Mr. Briggs was convicted of the offense of aggravated

robbery and was sentenced to 15 years imprisonment in the Texas Department of

Criminal Justice - Institutional Division. He was convicted in cause

number1430016 in the 263rd District Court of Harris County, Texas, styled

State of Texas v. Shaun Develle Briggs .

II.

The brief is currently due May 14, 2015. No extensions have been requested.

III.

Undersigned counsel is requesting 30 days from that due date until June 14,

2015.

IV.

Counsel has been working on a murder appeal in State v. Joe Lee Bowden.

record is lengthy;

On April 30, 2015, counsel filed a PDR in State v. Joshua London ;

On March 25, 2015, the Court of Criminal Appeals granted the State’s PDR

in Osmin Peraza v. State , N OS . PD-0100 & PD-0101-15. The CCA ordered expedited

briefing (15 days per side with no extensions of time permitted). Undersigned

counsel filed the brief on April 23, 2015. The CCA then set argument for May 20,

2015. This is also requiring additional time to prepare for argument.

Additionally, in January 2015, counsel made plans to attend a wedding and

graduation in Massachusetts from May 14-17, 2015. The tickets are nonrefundable.

This request is made not to delay the proceedings, but to ensure that Mr. Briggs

is adequately represented.

WHEREFORE, PREMISES CONSIDERED, Mr. Briggs respectfully prays

that this undersigned counsel be designated as the attorney of record in this cause

and that the Court permit an extension of time until June 14, 2015.

Respectfully submitted, ALEXANDER BUNIN Chief Public Defender Harris County Texas /s/ Jani Maselli Wood _______________________ JANI J. MASELLI WOOD Assistant Public Defender State Bar Number 00791195 Harris County Texas 1201 Franklin, 13th Floor Houston Texas 77002 (713) 368-0001 (713) 368-9278 (Fax) Jani.Maselli@pdo.hctx.net Attorney for Appellant, Shaun Develle Briggs CERTIFICATE OF SERVICE

Pursuant to Tex. R. App. Proc. 9.5, this certifies that on May 18, 2015, a

copy of the foregoing was emailed to counsel for the state (through texfile.com) at

the following address:

Alan Curry

Assistant District Attorney

1201 Franklin Street, 6th Floor

Houston, TX 77002

curry_alan@dao.hctx.net

/s/ Jani J Maselli Wood ___________________________________

JANI J. MASELLI WOOD