ACCEPTED
01-14-00333-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
1/5/2015 4:34:44 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00333-CR
In the
Court of Appeals FILED IN
For the 1st COURT OF APPEALS
HOUSTON, TEXAS
First District of Texas 1/5/2015 4:34:44 PM
At Houston CHRISTOPHER A. PRINE
Clerk
No. 1388778
In the 230th District Court of
Harris County, Texas
REGINALD HUTCHINS
Appellant
v.
THE STATE OF TEXAS
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 these cases, and, in support
thereof, presents the following:
1. In the 230th District Court of Harris County, Texas in cause number
1388778, the State of Texas v. Reginald Hutchins, appellant filed a
Motion to Suppress.
2. After the trial court denied appellant’s Motion to Suppress, appellant
pled guilty and was convicted of possession of a controlled
substance.
3. Appellant was sentenced to 5 years in the Texas Department of
Criminal Justice Institutional Division.
4. The State’s brief is due on January 8, 2015.
5. An extension of time in which to file the State’s brief is requested
until February 8, 2015.
6. Defendant requested, and this court granted, three previous
Extensions of Time in Which to File an Appellate Brief (July 9,
2014; September 4, 2014; October 8, 2014).
7. The State requested, and this court granted, one previous Extension
of Time in which to File an Appellate Brief (December 6, 2014).
8. The facts relied upon to explain the need for this extension are:
On January 2, 2015 I was informed that I would be
transferred from my assignment in the domestic violence division, in
which I had approximately 200 active cases, to an assigned
prosecutor role in a county criminal court at law. I am now
primarily responsible for over 500 cases, including all cases in which
there is a civilian victim, as well as approximately 25 cases currently
set for jury trial. In addition to these responsibilities, I am required
to spend more than four hours each day in the courtroom handling
each day’s docket. The State will not need any more extensions if
this court grants the State’s motion. This motion is not sought for
delay, but so that justice may be done.
WHEREFORE, the State prays that this Court will grant an extension of time
until November 3, 2014 in which to file the State’s brief in this case.
Respectfully submitted,
/s/ Joe Bramanti
Joe Bramanti
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-0657
TBC No. 24081580
bramanti_joe@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been served to the
appellant’s attorney at the following address on January 5, 2015:
Tonya Rolland
4301 Yoakum Blvd.
Houston, TX 77006
Fax: 713-453-2203
/s/ Joe Bramanti
Joe Bramanti
Assistant District Attorney
Harris County, Texas
bramanti_joe@dao.hctx.net
Date: January 5, 2015