ACCEPTED
FIRST COURT OF APPEALS
HOUSTON, TEXAS
1/21/2015 5:13:47 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00581-CR
In the FILED IN
Court of Appeals 1st COURT OF APPEALS
HOUSTON, TEXAS
For the 1/21/2015 5:13:47 PM
First Judicial District of Texas CHRISTOPHER A. PRINE
At Houston Clerk
No. 1933896
In the County Criminal Court at Law Number 2 of
Harris County, Texas
BRODIES E. MYLES
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 10.1(a)
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. In the County Criminal Court at Law Number 2 of Harris County, Texas, in
The State of Texas v. Brodies E. Myles, Cause Number 1933896, appellant was
charged with driving with a suspended license.
2. Appellant was sentenced to three days incarceration in the Harris County Jail
and a $100 fine.
3. The State’s brief was due on January 21, 2015.
5. An extension of time in which to file the State’s brief is requested until February
20, 2015.
6. No previous extension has been requested by the State.
7. The facts relied upon to explain the need for this extension are:
a) The undersigned attorney was assigned this case in December 2014;
b) Since the undersigned attorney was assigned this case, the attorney finished
writing the State’s briefs in the following cases:
(1) Cause Number 01-13-00931-CR, Melissa Dromgoole, Appellant v. The State
of Texas, Appellee, which involves four points of error and thirteen
volumes of the reporter’s record;
(2) Cause Number 01-13-00822-CR, Gregorio Guerrero, Appellant v. The State of
Texas, Appellee, which involves one points of error and three volumes of
the reporter’s record; and
(3) Cause Number 14-14-00152-CR, David Dean Harris, Appellant v. The State
of Texas, Appellee, which involves three points of error and fourteen
volumes of the reporter’s record.
c) The undersigned attorney is also currently engaged in the preparation of the
State’s Brief in the following appellate cause numbers:
(1) Cause Numbers 01-14-00400-CR, Timothy Wayne Fisher, Appellant v. The
State of Texas, Appellee, which involves one point of error, with four
subpoints of error, and fifteen volumes of the reporter’s record;
(2) Cause Number 14-14-00386-CR, Rodney Rochell, Appellant v. The State of
Texas, Appellee, which involves one point of error and five volumes of
the reporter’s record;
(3) Cause Number 14-14-00473-CR, Jimmy Earl Van-Cleave, Appellant v. The
State of Texas, Appellee, which involves two points of error and four
volumes of the reporter’s record;
(4) Cause Numbers 01-12-00447-CR and 01-12-00448-CR, Samuel Espinoza
Rodriguez, Appellant v. The State of Texas, Appellee, which involves fourteen
points of error and nine volumes of the reporter’s record; and
(5) Cause Number 01-14-00421-CR, Eric Dewayne Small, Appellant v. The State
of Texas, Appellee, which involves six points of error and eight volumes of
the reporter’s record.
WHEREFORE, the State prays that this Court will grant an extension of time until
February 20, 2015 in which to file the State’s brief in this case.
Respectfully submitted,
/s/ Carly Dessauer
________________________________________________________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served to
appellant’s attorney on January 21, 2015 through TexFile:
Angela L. Cameron
Assistant Public Defender, Harris County
1201 Franklin Street, 13th Floor
Houston, Texas 77002
angela.cameron@pdo.hctx.net
/s/ Carly Dessauer
________________________________________________________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
curry_alan@dao.hctx.net
Date: January 21, 2015
Brodies E. Myles v. State
Combined Opinion