Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/2/2015 10:18:29 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00765-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/2/2015 10:18:29 AM CHRISTOPHER PRINE CLERK I N THE F IRST D ISTRICT C OURT OF A PPEALS
N O . 01-15-00764-CR, 01-15-00765-CR, 01-15-00766-CR
C ORY N ICKERSON
A PPELLANT On Appeal from Nos. 1404004, 1416652, 1459622
From the 176 th District Court
Harris County, Texas
V.
T HE S TATE OF T EXAS
A PPELLEE
A PPELLANT ’ S M OTION FOR E XTENSION
TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS:
COMES NOW, Cory Nickerson, and files this Motion to Extend Time to File Brief,
and in support thereof, would respectfully show the Court the following:
I.
Appellant’s brief was due November 18, 2015. There have been no previous motions
for extension of time to file Appellant’s Brief.
II.
Counsel requests an extension due primarily to the fact that she has been engaged in
work in the Harris County Public Defender’s Office on many cases, include the
following:
Lenin Lopez, 01-13-01079-CR, reversed and set for rehearing in cause #1403196
Ruben Totten, PD-0483-15 (PDR granted)
Hugo Pachas-Lunas, 01-14-00516-CR, etc.
Michael Davila, 01-15-00560-CR
Stephen Hopper, 14-15-00371-CR
Domingo Medina, 01-15-00575-CR
Kori Henegar, 14-15-00529-CR
Craig Beal, 01-12-00896-CR
Joseph Smith, 14-15-00625-CR
Emanuel Hayes, 1408364
Research and writing in preparation for several cases for the trial division of
the Harris County Public Defender’s Office.
III.
Appellant’s attorney requests this extension which is necessary so that the brief can be
thoroughly written and timely filed. This motion is not made for the purpose of delay.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable
Court grants this extension for an additional 30 days to January 2, 2015.
Respectfully Submitted, A LEXANDER B UNIN Chief Public Defender Harris County, Texas /s/ Sarah V. Wood S ARAH V. W OOD Assistant Public Defender Texas Bar Number 24048898 1201 Franklin, 13 th Floor Houston, Texas 77002 Phone: (713) 368-0016 Fax: (713) 368-9278 Sarah.Wood@pdo.hctx.net Certificate of Service
By my signature below, I hereby certify that a true and correct copy of the above and
foregoing has been served upon the Harris County District Attorney's Office – Alan
Curry, via the electronic filing service.
/s/ Sarah V. Wood
Sarah V. Wood