The opinion
ACCEPTED
01-15-00183-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/31/2015 11:32:49 AM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS FOR THE
FIRST COURT OF APPEALS DISTRICT
No. 01-15-00183-CR FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
ROY VASQUEZ 7/31/2015 11:32:49 AM
Appellant, CHRISTOPHER A. PRINE
Clerk
On Appeal From the 230th
V. District Court of Harris County
Trial Cause Number 1437421
THE STATE OF TEXAS
Appellee
APPELLANT'S FINAL MOTION TO EXTEND TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Roy Vasquez, Appellant in the above cause, would respectfully request that the Court
grant his motion to extend the time to file his brief. In support of said motion, Appellant
would show unto the Court the following:
I.
This appeal lies from the Appellant's conviction in The State of Texas v. Roy Vasquez,
cause number 1437421 in the 230th District Court of Harris County, Texas. The Appellant
was charged by indictment with aggravated sexual assault on August 8, 2014. The Appellant
was found guilty of the lesser-included offense of sexual assault on February 12, 2015,
following a jury trial. The Appellant was sentenced to seventeen (17) years confinement in
the Texas Department of Corrections – Institutional Division. Two previous extensions have
been requested and granted. The Appellant’s completed brief is being filed simultaneously
with this motion.
II.
Appellant's attorney of record has not been able to timely file the brief for the
following reasons:
1. A direct appeal brief in Jeremy Washington v. State of Texas, cause number
1862655, which was submitted on July 13, 2015;
2. A direct appeal brief in Kenneth Brown v. State of Texas, cause number
1389982, which is due on August 5, 2015;
3. A direct appeal brief in Sylvia Collins v. State of Texas, cause number
1390220, which is due on August 17, 2015;
4. Investigation for a potential Motion for New Trial in Alton Jolivette v.
State of Texas, cause numbers 1428512, 1428510 & 1428708, which
would be due on August 24, 2015.
III.
An extension of time is necessary so that the brief can be timely filed. This motion is
not made for the purpose of delay.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable
Court will grant this requested extension of time to file the Appellant's Brief in the above
cause and extend the time for filing the brief to today, July 31, 2015.
Respectfully submitted,
Alexander Bunin
Chief Public Defender
/s Mark Kratovil______________
Mark Kratovil
State Bar No. 24076098
Harris County Public Defender’s Office
Assistant Public Defender
1201 Franklin, 13th Floor
Houston, Texas 77002
Tel: (713)274-6728
e-Fax: (713)437-4339
CERTIFICATE OF SERVICE
I certify that on July 31, 2015, a copy of the foregoing instrument has been served
upon the State of Texas by electronic delivery to the Appellate Division of the Harris County
District Attorney’s Office.
/s Mark Kratovil
MARK KRATOVIL