Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 10/9/2015 2:42:50 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00444-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 10/9/2015 2:42:50 PM CHRISTOPHER PRINE CLERK No. 1-15-00444-CR, 01-15-00445-CR, 01-15-00446-CR

In the

Court of Appeals

For the First District of Texas At Houston

 No. 1378279, 1458347, 1458348 In 230 th District Criminal Court  BRANDON TODERICK JOHNSON, 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 T EX . R. A PP . 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 three aggravated robberies (RR1 3).

Appellant entered a plea of guilty to all three offenses (RR1 4). The jury

found him guilty as charged and assessed punishment in each case at 40

years in the Institutional Division of the Texas Department of Criminal

Justice (RR2 12). Appellant filed timely notice of appeal, and the court

certified his right to appeal (CR-156, 158).

2. The State’s brief was due October 8, 2015. The State hereby requests an

extension for the filing of the State’s brief until November 9, 2015.

3. The following facts are relied upon to show good cause for an extension

of time to allow the State to file its brief:

The State has been working on and has filed the following briefs in the last

thirty days.

Moreno v. State

1-15-00441-CR

State’s Brief filed September 18, 2015

Trigo v. State

01-15-00382-CR

State’s Brief filed September 24, 2015

Rodriguez v. State

1-15-00135-CR

State’s Brief due September 30, 2015

Furthermore, the undersigned attorney has been assigned the following

briefs in addition to the brief in this cause number.

Uddin v. State

14-15-00082-CR

State’s Brief due October 12, 2015

Briones v. State

01-14-00121-CR

State’s Brief due October 15, 2015

Dunn v. State

14-15-00340-CR

State’s Brief due October 26, 2015

4. This is the State’s first request for an extension of time to file its brief.

WHEREFORE, the State prays that this Court will grant the requested

extension.

Respectfully submitted, /s/ Kimberly Stelter K IMBERLY S TELTER Assistant District Attorney 1201 Franklin, Suite 600 Houston, Texas 77002-1923 (713) 755-5826 Stelter_Kimberly@dao.hctx.net TBC No. 19141400 *4 CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument will be served by

efile.txcourts.gov to:

Thomas Lewis

Attorney at Law

1602 Washington Ave.

Houston, TX 77007

/s/ Kimberly Stelter K IMBERLY S TELTER Assistant District Attorney 1201 Franklin, Suite 600 Houston, Texas 77002-1923 (713) 755-5826 10/9/15