Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 11/12/2015 4:14:52 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00636-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 11/12/2015 4:14:52 PM CHRISTOPHER PRINE CLERK No. 01-15-00636-CR In the

Court of Appeals for the

First District of Texas At Houston

 No. 1409330

In the 232nd District Court Of Harris County, Texas  IRVIN NOTIAS Appellant

v. THE STATE OF TEXAS Appellee

 STATE’S MOTION FOR EXTENSION OF TIME

IN WHICH TO FILE AN 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 an extension of time in which to file the State’s Brief in this cause, and,

in support thereof, presents the following:

1. On June 30, 2015, appellant was convicted by a jury of aggravated robbery

with a deadly weapon and sentenced to 40 years in the Institutional Division

of the Texas Department of Criminal Justice.

2. Appellant filed a timely written notice of appeal.

3 . The State’s Brief is due on November 12, 2015.

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

December 14, 2015. No previous extensions have been granted.

5. The following facts are relied upon to show good cause for the requested

extension:

i. The undersigned attorney has been engaged in the preparation

of the State’s Brief in Cause No. 01-15-00226-CR, Weylin

Wayne Alford, Appellant v. The State of Texas, Appellee , which

was filed on November 11, 2015.

ii. The undersigned attorney has been engaged in the preparation

of the State’s Brief in Cause No. 14-15-00740-CR, Russell Levi

Pope, Appellant v. The State of Texas, Appellee , which was

filed on October 30, 2015.

iii. The undersigned attorney has been engaged in the preparation

of the State’s Brief in Cause No. 14-15-00251-CR, Derek

James Strimban, Appellant v. The State of Texas, Appellee ,

which is due to be filed on November 16, 2015.

WHEREFORE, the State prays that this Court will grant an additional

extension of time until December 14, 2015 in which to file the State’s Brief in this

cause.

Respectfully submitted, /s/ Heather A. Hudson H EATHER A. H UDSON Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 State Bar No. 24058991 hudson_heather@dao.hctx.net curry_alan@dao.hctx.net CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument has been submitted

for service by e-filing to the following address:

Joseph W. Varela

2500 East T.C. Jester Blvd.

Suite 247

Houston, Texas 77008

(713) 957-0440

jwvarela@gmail.com

/s/ Heather A. Hudson H EATHER A. H UDSON Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 State Bar No. 24058991 Date: November 12, 2015