Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/4/2015 5:11:40 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00268-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/4/2015 5:11:40 PM CHRISTOPHER PRINE CLERK No. 01-15-00268-CR In the

Court of Appeals

For the First District of Texas At Houston ♦

No. 1450059

th In the 177 District Court Of Harris County, Texas ♦ TONI TAVAREZ

Appellant THE STATE OF TEXAS v. Appellee

♦ STATE’S SECOND 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. The following facts are

relevant: 1.

The appellant was indicted for murder. (CR 8). The appellant pleaded

not guilty, but a jury found her guilty as charged. (CR 329, 340). The

jury assessed punishment at fifty years’ confinement. (CR 339, 340).

The trial court certified the appellant’s right of appeal, and the appellant filed a timely notice of appeal. (CR 313, 343).

2.

The State’s brief is due on December 4, 2015. The State requests a 30-day extension of time in which to file its brief.

3. This is the State’s second request for extension.

4.

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

extension of time to allow the State to file its brief: a.

Since this Court granted the State’s first motion for extension

on November 4, 2015, the undersigned attorney has worked on

the following matters:

1. Christopher Dewa Washington

No. 01-14-00366-CR

Oral argument held November 4, 2015

Motion for rehearing filed November 23, 2015

2. Augustus Mitchell

No. 01-15-00397-CR

Brief filed November 6, 2015

3. Joseph Juan Facundo

No. 01-15-00279-CR

Brief filed November 25, 2015

4. Leiroi Mikele Daniels

No. 14-15-00111-CR

Brief filed December 3, 2015

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

extension.

Respectfully submitted, C LINTON A. M ORGAN /s/ C.A. Morgan Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 713.274.5826 morgan_clinton@dao.hctx.net TBC No. 24071454 *4 CERTIFICATE OF SERVICE I certify that I have requested that efile.txcourts.gov electronically serve

a copy of this motion to:

Daucie Schindler

daucie.schindler@pdo.hctx.net

C LINTON A. M ORGAN /s/ C.A. Morgan Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 713.274.5826 morgan_clinton@dao.hctx.net TBC No. 24071454 Date: December 4, 2015