*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 8/6/2015 3:18:29 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-15-00257-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 8/6/2015 3:18:29 PM CHRISTOPHER PRINE NO. 14-15-00257-CR CLERK

IN THE COURT OF APPEALS

FOR THE FOURTEENTH DISTRICT OF TEXAS

AT HOUSTON

JONATHAN YOUNG,

Appellant §

§

vs. §

§

THE STATE OF TEXAS, Appellee §

MOTION FOR EXTENSION OF TIME TO FILE BRIEF

ON APPEAL FROM CAUSE NO. 1421419

IN THE 183 rd DISTRICT COURT OF HARRIS COUNTY, TEXAS

Phone: (713) 256-6779

Fax: (713) 861-2951

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW JONATHAN YOUNG, APPELLANT, and moves the Court to

extend the time for filing a brief herein, and in support thereof would show as follows:

I.

Appellant was convicted of the offense of delivery of a controlled substance

in an amount greater than 400 grams and sentenced on March 6, 2015 to a term of

30 years in prison.

II.

The brief herein is due on August 5, 2015. Appellant’s counsel is a sole

practitioner and is currently preparing briefs on three other cases. Appellant’s

counsel has just completed a brief in a capital murder case, Tyran Riley v. State, 14-

14-00081-CR, filed on this date.

III.

Appellant counsel requests an extension of 35 days, making the brief due on

September 9, 2015, so the Appellant may receive effective assistance of counsel.

WHEREFORE, PREMISES CONSIDERED, Defendant prays this Court to

grant this Motion and extend the time for the filing of a brief herein.

Respectfully submitted,

Phone: (713) 256-6779

Fax: (713) 861-2951

CERTIFICATE OF SERVICE

I the undersigned attorney certify that a true copy of the foregoing was served

on the District Attorney of Harris County, Texas, by e-mail delivery to

Curry_Alan@dao.hctx.net on this the 6 th day of August, 2015.

______________

Thomas J. Lewis