ACCEPTED
01-14-00962-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
1/6/2015 10:44:34 AM
CHRISTOPHER PRINE
CLERK
No. 01-14-00962-CR
In the FILED IN
Court of Appeals 1st COURT OF APPEALS
HOUSTON, TEXAS
For the
1/6/2015 10:44:34 AM
First District of Texas CHRISTOPHER A. PRINE
At Houston Clerk
No. 1446229
In the 208th District Court
Of Harris County, Texas
THE STATE OF TEXAS
Appellant
v.
JIMMY EARL DRUMMOND
Appellee
STATE’S MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE 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 extension of
time in which to file the State’s brief in this case, and, in support thereof, presents the
following:
1. On November 10, 2014, in cause number 1446229, in the 208th District Court of
Harris County, Texas, the trial court granted the appellee’s motion to quash the information
and dismiss the prosecution in The State of Texas v. Jimmy Earl Drummond.
2. The State timely filed a written notice of appeal on November 18, 2014.
3. The State’s brief is due on January 7, 2015.
4. An extension of time in which to file the State’s brief is requested until January 30,
2015.
5. No previous extensions have been granted to the State.
6. The facts relied upon to explain the need for this extension are:
During this time period, the undersigned attorney is set to testify at a very
lengthy hearing on the defendant’s application for a post-conviction writ of
habeas corpus in Ex parte David Mark Temple. The undersigned attorney is also
preparing the State’s brief in Marcos M. Flores v. The State of Texas, Cause Number
14-14-00663-CR. With his numerous additional duties as Chief of the Appellate
Division, the undersigned assistant district attorney has needed some additional
time in order to respond to the appellant’s brief in this case.
WHEREFORE, the State prays that this Court will grant an extension of time until
January 30, 2015 in which to file the State’s brief in this case.
Respectfully submitted,
/s/ Alan Curry
ALAN CURRY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 05263700
curry_alan@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been mailed to the
following address on January 6, 2015:
Samuel R. Cammack, III
Attorney at Law
1001 West Loop South, Suite 700
Houston, Texas 77027-9033
/s/ Alan Curry
ALAN CURRY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 05263700
curry_alan@dao.hctx.net
Date: January 6, 2015