Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 10/22/2015 11:41:27 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00487-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 10/22/2015 11:41:27 AM CHRISTOPHER PRINE CLERK NO. 01-15-00487-CR IN THE COURT OF APPEALS FIRST DISTRICT HOUSTON, TEXAS NO. 1416994 IN THE TRIAL COURT 230 TH JUDICIAL DISTRICT HARRIS COUNTY, TEXAS FREDIS MAURICIO FLORES § APPELLANT

VS. §

THE STATE OF TEXAS § APPELLEE

MOTION FOR EXTENSION OF TIME FOR FILING APPELLANT'S BRIEF ALLEN C. ISBELL 2016 Main St., Suite 110 Houston, Texas 77002 713/236-1000 Fax: 713/236-1809 STATE BAR NO. 10431500 Email:allenisbell@sbcglobal.net COUNSEL ON APPEAL *2 TO THE HONORABLE COURT OF APPEALS:

COMES NOW FREDIS MAURICIO FLORES, appellant, by and through

his retained counsel on appeal, and respectfully requests this Honorable

Court grant an Extension of Time for Filing an Appellant's Brief. The present

date for filing the Brief is October 26, 2015, and it is respectfully requested

that said time be extended until November 25, 2015. For cause, appellant

would show the Court as follows:

I.

On May 14, 2015, appellant was convicted of Driving While Intoxicated

(3 rd Offender), in the 230 th District Court of Harris County, Texas entitled The

State of Texas vs. FREDIS MAURICIO FLORES , in Cause Number 1416994

and was sentenced to four (4) years confinement in the Texas Department of

Criminal Justice, Institutional Division. No Motion for New Trial was filed and

written Notice of Appeal was given May 21, 2015.

II.

Counsel is unable to timely file the Brief within the time period from the

first extension of filing the Reporter’s Record for the following reasons:

1. Counsel is preparing for the following Trials:

• State vs. Simon, No. 1391357 (Capital Murder)(set to begin

October 22, 2015);

• State vs. Aguilar, No. 1370058 (Murder).

2. Counsel has recently represented the following in court: State vs.

Aguilar, No. 1370058; State vs. Allen, Nos. 1475254 & 1403306;

State vs. Caplan, No. 1449686; State vs. Collins, No. 1468713;

State vs. Cornelius, No. 1483722; State vs. Dornes, No.

1477372; State vs. Hastings, No. 1464287; State vs. Hornsby,

Nos. 1455466, 1455467 & 1455768; State vs. Johnson, No.

1485392; State vs. Joyner, No. 1358039; State vs. Koch, No.

1473727; State vs. Landon, No. 1370845; State vs. Nuñez-

Reyes, No. 1476299; State vs. Palmer, No. 1419391; State vs.

Sanfelippo, No. 1479165; State vs. Simon, No. 1391357; State vs.

Taylor, No. 1481280; State vs. Vallier, No. 1480767; State vs.

Zumoff, No. 1485229;

III.

Counsel feels that if the additional time is granted, the Brief in this cause

will be filed timely.

IV.

This is the second (2 nd ) extension requested.

V.

This motion is urged at the first opportunity as appellant will suffer

irremediable harm if it is not granted.

WHEREFORE, PREMISES CONSIDERED, appellant prays that this

Honorable Court grant this extension of time in which to file the Appellant's

Brief until November 25, 2015.

Respectfully submitted, /s/ Allen C. Isbell ALLEN C. ISBELL 2016 Main St., Suite 110 Houston, Texas 77002 713/236-1000 Fax No. 713/236-1809 STATE BAR NO. 10431500 Email: allenisbell@sbcglobal.net COUNSEL ON APPEAL Certificate of Service I hereby certify that on this 22 nd day of October, 2015, a true and correct

copy of the foregoing motion was sent to the District Attorney's Office,

Appellate Division, and to Mr. Fredis Mauricio Flores, appellant.

/s/ Allen C. Isbell ALLEN C. ISBELL Certificate of Compliance The undersigned attorney on appeal certifies this motion is computer

generated and consists of 561 words. Counsel is relying on the word count

provided by the Word Perfect computer software used to prepare the motion.

/s/ Allen C. Isbell ALLEN C. ISBELL