Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 12/31/2015 9:54:53 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00275-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/31/2015 9:54:53 AM CHRISTOPHER PRINE CLERK No. 01-15-00275-CR In the

Court of Appeals for the

First District of Texas At Houston

 No. 1390115

In the 183rd District Court Of Harris County, Texas  WALTER HARVEY BALLARD, JR. Appellant

v. THE STATE OF TEXAS Appellee

 STATE’S SECOND 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 February 26, 2015, appellant was convicted by a jury of possession of

child pornography and sentenced to a term of 13 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 was due on December 30, 2015.

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

January 29, 2016.

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. 14-15-00432-CR, Amos

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

filed on December 11, 2015.

ii. The undersigned attorney has been engaged in the preparation

of the State’s Brief in Cause No. 01-15-00636-CR, Irvin Notias,

Appellant v. The State of Texas, Appellee , which is due to be

filed on January 13, 2016.

iii. The undersigned attorney was on vacation from December 12,

2015 through December 19, 2015.

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

extension of time until January 29, 2016 in which to file the State’s Brief in this

cause.

Respectfully submitted, *3 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:

Maverick Ray

1419 Franklin St.

Houston, Texas 77002

(713) 389-0940

maverickraylaw@gmail.com

1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 State Bar No. 24058991 Date: December 31, 2015