Case Information
*1
No. 01-14-00758-CR
In the Court of Appeals For the First District of Texas At Houston
No. 1401233 In the District Court Of Harris County, Texas
RICHARD CONTRERAS
Appellant V.
THE STATE OF TEXAS
Appellee
STATE'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE COURT OF APPEALS:
THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 2 & 10.5, moves for an extension of time in which to file its appellate brief and in its motion, would show the Court the following:
- The appellant was charged with the aggravated sexual assault of a child committed on July 1, 2013 (CR - 15). He pled "guilty" to the charge (CR - 23-32). The trial court sentenced him to 50 years in prison on June 10, 2014 (CR - 38). The appellant filed a motion for new trial that same day, which was denied on August 15 (CR - 41-46). The appellant then
*2 filed a notice of appeal on September 4, 2014, and the trial court certified that he had waived his right to appeal (CR - 34, 57). 2. The State's brief is due on June 12, 2015. The State hereby requests a 30-day extension for the filing of the State's brief. 3. The following facts are relied upon to show good cause for an extension of time to allow the State to file its brief: a. The record in this case is over 130 megabytes in length split over ten files and will take some time to process. b. The undersigned attorney researched and answered by email more than 50 legal questions of trial prosecutors since the appellant filed his brief. The undersigned attorney researched and answered even more such questions by phone during that time period. c. The undersigned attorney has been involved in completing the following written appellate project since the appellant filed his brief: (1) Johnathan Castaneda v. The State of Texas
No. 01-14-00389-CR No. 01-14-00390-CR Brief filed May 18, 2015 (2) Griselda Aza v. The State of Texas
No. 14-14-00241-CR No. 14-14-00242-CR Brief to be filed June 26, 2015
*3
WHEREFORE, the State prays that this Court will grant the requested extension. Respectfully submitted, /s/ Eric Kugler ERIC KUGLER Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 (713) 755-5826
Kugler_eric@dao.hctx.net TBC No. 796910
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served by efile.txcourts.gov to:
Michael Driver Attorney at Law 402 Main, 4th floor Houston, TX 77002 Mikedriverlaw@gmail.com /s/ Eric Kugler Eric Kugler Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 (713) 755-5826
TBC No. 796910 Date: June 12, 2015