ACCEPTED
04-14-00878-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
1/21/2015 7:42:08 PM
KEITH HOTTLE
CLERK
No. 04-14-00878-CR
In the FILED IN
Court of Appeals 4th COURT OF APPEALS
SAN ANTONIO, TEXAS
for the
1/21/2015 7:42:08 PM
Fourth District of Texas
KEITH E. HOTTLE
Clerk
No. 2013CR10841W
In the 437th District Court
Bexar County, Texas
MATTHEW DOUGLAS HAYES
Appellant
V.
THE STATE OF TEXAS
Appellee
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE APPELLATE BRIEF
TO THE HONORABLE COURT OF APPEALS:
APPELLANT, pursuant to TEX. R. APP. P. 10.1, 10.5(b) and 38.6(d), moves
for an extension of time within which to file its appellate brief. In support of its
motion, appellant submits the following:
1. Appellant was charged with aggravated robbery.
2. Appellant pled guilty to the charged offense and submitted to a pre-
sentence investigation. After a hearing, the court sentenced appellant to
7 years confinement in the Institutional Division of the Texas
Department of Criminal Justice on September 9, 2014.
3. Notice of appeal was filed on December 16, 2014.
4. Appellant’s brief is due on January 21, 2015.
5. Appellant seeks an extension to file his brief until March 20, 2015.
6. The following facts are relied upon to show good cause for the
requested extension:
a. Counsel has been acting as co-counsel on a case involving Garcia
Glen White. Mr. White is set to be executed on January 28, 2015.
b. Counsel had to prepare for a hearing in another capital case, Ex parte
Williams, Cause No. 1088181-A that was held on January 14, 2015.
c. Counsel has filed subsequent writs in Ex parte Williams, Cause Nos.
1088181-B and 1088181-C.
7. Appellant’s motion is not for purposes of delay, but so that justice may
be done.
WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted,
/s/MANDY MILLER
Attorney for appellant
2910 Commercial Center Blvd., Ste. 103-201
Katy, TX 77494
SBN 24055561
PHONE (832) 900-9884
FAX (877) 904-6846
mandy@mandymillerlegal.com
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CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been delivered via
email to the following address:
Bexar County District Attorney’s Office
ATTN: Rico Valdez
/s/MANDY MILLER
Attorney for appellant
2910 Commercial Center Blvd., Ste. 103-201
Katy, TX 77494
SBN 24055561
PHONE (832) 900-9884
FAX (877) 904-6846
mandy@mandymillerlegal.com
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