PD-0124-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 2/2/2015 12:00:00 AM
Accepted 2/4/2015 11:52:31 AM
ABEL ACOSTA
CLERK
IN THE UNITED STATES COURT OF CRIMINAL APPEALS
" 5™ Courtof Appeals Number 05-14-0002V-CR
Trial Court: County Court at Law No 2. 002-80051-3031,
MELLANNISE HENDERSON
PETITIONER
V.
THE STATE OF TEXAS
Petitioner
PETITIONER'S MOTION FOR EXTENSION OF TIME AND
ALTERNATIVE MOTION TO FILE BRIEF OUT OF TIME
Law Office of Mellannise Henderson-Love, P.L.L.C.
/s/Mellannise Henderson-Love
FILED IN
COURT OF CRIMINALAPPEALS
February 4, 2015
ABEL ACOSTA, CLERK
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COMES NOW Mellannise Henderson, Petitioner herein and files this Motion for Extension
of Time, and Alternative Motion to File Briefout of Time and will show unto the Court the
following:
On December 2, 2014, the Court of Appeals rendered a decision affirming the Trial
Court's opinion. Petitioner's deadline to file her Petition for Discretionary Review was January
16, 2014. Petitioner is seeking a Motionfor Extension of Time, and Alternative Motion to File Brief
out of Time.
By way of background, Petitioner had an unexpected medical procedure in January
that required her to take two weeks off from work. The two weeks off, required Petitioner to
play catch up upon her return. Because of the time off from work, Petitioner is seeking
additional time to file her brief- deeming the Petitioner's brief timely filed on January 31, 2015.
This Motion is timely filed within 15 days of the initial brief being due. Moreover,
Respondent will not be harmed by the filing of this Motion; moreover, this Motion is not
sought for delay but so that justice may be ultimately served.
CONCLUSION:
Based on the forgoing argument, Petitioner is asking of this Court to GRANT the
requested Motion, and any and all relief to which she may be legally entitled.
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Law Office of Mellannise Henderson-Love, PLLC
/s/Mellannise Henderson-Love
Attorney for Petitioner
State Bar No. 0079674
Mlove@lovelawtx.com
3102 Maple Avenue, Suite 400
Dallas, Texas 75201
Tel: (214) 638-8777
Fax: (214) 291-5331
CERTIFICATE OF SERVICE
The undersigned Counsel hereby certifies that on January 31, 2015, a true and correct
copy of Petitioner's Motion was served via electronic mail on:
Collin County District Attorney Gregg Willis,
2100 Bloomdale, Suite 2400 Counsel for Respondent
McKinney Texas 75071.
/s/Mellannise Henderson-Love
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