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:

1. The appellant was charged with the aggravated robbery of Maria Estrada committed on August 13, 2013 (CR - 15). He pled "not guilty" to the charge, and the case was tried to a jury (CR - 183). The jury found the appellant guilty and sentenced him to 20 years in prison on August 22, 2014 (CR - 183). The appellant filed notice of appeal three days later,

*2 and the trial court certified that he had the right to appeal (CR - 186188). 2. The State's brief was originally due on May 15, 2015, but this Court granted an extension until June 15, 2015. The State hereby requests a second 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 eighteen megabytes in length split over seven volumes and will take some time to process. b. The undersigned attorney researched and answered by email more than 80 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 is responsible for supervising six other appellate prosecutors, and has spent a substantial amount of time reviewing the briefs of those prosecutors, attending their oral arguments, and assisting in the preparation of both during that time period. The undersigned attorney has also been responsible for training two new appellate prosecutors, which requires more intense supervision and editing, and therefore, more of a time commitment. d. The undersigned attorney has been involved in completing the following written appellate project since the appellant filed his brief: (1) Elder Somoza v. The State of Texas

No. 01-14-00716-CR Brief filed April 15, 2015

*3 | (2) | In the Interest of B.D.S. v. The State of Texas | | :--: | :--: | | | No. 01-14-00762-CV | | | Brief filed April 28, 2015 | | (3) | Jose Vasquez v. The State of Texas | | | No. PD-0078-15 | | | Brief on PDR filed May 12, 2015 | | (4) | Antonio Perez v. The State of Texas | | | No. 01-12-01001-CR | | | PDR filed May 12, 2015 | | (5) | Johnathan Castaneda v. The State of Texas | | | No. 01-14-00389-CR | | | No. 01-14-00390-CR | | | Brief filed May 18, 2015 | | (6) | Griselda Aza v. The State of Texas | | | No. 14-14-00241-CR | | | No. 14-14-00242-CR | | | Brief to be filed June 26, 2015 |

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

*4

CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument will be served by efile.txcourts.gov to:

Sarah Wood
Assistant Public Defender
Harris County, Texas
1201 Franklin, ${13}^{\text{th}}$ Floor
Houston, Texas 77002
Sarah.wood@pdo.hctx.net

Is/ 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 15, 2015