The opinion
ACCEPTED
01-15-00268-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/4/2015 4:39:10 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00268-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
For the 11/4/2015 4:39:10 PM
First District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston
♦
No. 1450059
In the 177th District Court
Of Harris County, Texas
♦
TONI TAVAREZ
Appellant
v.
THE STATE OF TEXAS
Appellee
♦
STATE’S FIRST MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
♦
To the Honorable Court of Appeals:
The State of Texas, pursuant to TEX. R. APP. 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 November 4, 2015. The State requests a
30-day extension of time in which to file its brief.
3. This is the State’s first 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. This case was assigned to the undersigned attorney on October
14, 2015. Since then, the undersigned attorney has worked on
the following matters:
1. Ex parte Hugo Steve Ramirez
No. 14-15-00323-CR
Brief filed October 21, 2015
2. Marcus Jamez Lewis
No. 14-14-00779-CR
Oral argument held October 28, 2015
3. Judist Broussard
No. 01-15-0074-CR
Brief filed October 30, 2015
4. Stuart Adam Latham
No. 01-15-00139-CR
Brief filed November 3, 2015
5. Christopher Dewa Washington
No. 01-14-00366-CR
Oral argument held November 4, 2015
b. On October 19, 2015, the undersigned attorney took the
examination for board certification in criminal appellate law.
Preparation for this exam consumed considerable time on
nights and weekends, preventing the undersigned attorney
from putting in extra time on pending briefs.
WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted,
/s/ C.A. Morgan
CLINTON 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
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
/s/ C.A. Morgan
CLINTON 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: November 4, 2015