Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 6/29/2015 3:51:30 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-14-00444-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 6/29/2015 3:51:30 PM CHRISTOPHER PRINE CLERK 01-14-00444-CR In the Court of Appeals For the First District of Texas At Houston  No. 1411387 In the 248th District Court of  B LAKE A LAN C OTTON Appellant v.

T HE S TATE OF T EXAS 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 248 district court of Harris County, Texas, cause 1421756, the State of

Texas v. Blake Alan Cotton , appellant, was convicted of burglary of a building.

2. He was assessed punishment of confinement for 6 months in a state jail

facility.

3. The State’s brief is due on June 29, 2015.

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

29, 2015.

5. No previous extension has 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 14-13-

00370-CR, 01-14-00861-CR, 14-14-00696-CR, 01-14-00857-CR, and 01-14-

00834-CR. Additionally, in the last month, I prepared for and participated in an

abatement hearing in cause 14-13-00767-CR, and a motion to quash the

indictment in cause number 1465805. Additionally, I answer trial court

questions from other prosecutors 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 July 29, 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 June 29, 2015:

Emily Detoto

917 Franklin, 4 Floor

Houston, TX 77002

Abbie Miles Date: June 29, 2015