Jeremy Thomas v. State

ACCEPTED 01-11-00258-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/29/2014 6:01:45 PM CHRISTOPHER PRINE CLERK No. 01-11-00258-CR In the FILED IN 1st COURT OF APPEALS Court of Appeals HOUSTON, TEXAS For the 12/29/2014 6:01:45 PM First District of Texas CHRISTOPHER A. PRINE Clerk At Houston  No. 1284896 In the 177th District Court Of Harris County, Texas  JEREMY THOMAS Appellant V. THE STATE OF TEXAS Appellee  STATE’S MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE APPELLATE BRIEF  TO THE HONORABLE COURT OF APPEALS: THE STATE OF TEXAS, 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, the State submits the following: 1. Appellant was convicted for the offense of murder and sentenced to life confinement. 2. Appellant filed written notice of appeal on March 22, 2011. 3. Appellant filed his brief on November 12, 2014. 4. The State’s reply brief is due on December 12, 2014. 5. The State seeks an extension until January 31, 2015, to file its brief. 6. This is the State’s first request for an extension in this case. 7. The following facts are relied upon to show good cause for the requested extension: For reasons unknown, this case was not assigned to me until December 19, 2014, a date past the due date. 2 WHEREFORE, the State prays that this Court will grant the requested extension. Respectfully submitted, /s/ Dan McCrory DAN MCCRORY Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1901 (713) 755-5826 TBC No. 13489950 CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument has been mailed to the following email address via TexFile: Sarah V. Wood Assistant Public Defender Sarah.Wood@pdo.hctx.net /s/ Dan McCrory DAN MCCRORY Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1901 (713) 755-5826 TBC No. 13489950 Date: December 29, 2014 3