ACCEPTED
14-14-00278-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
1/28/2015 6:57:20 AM
CHRISTOPHER PRINE
CLERK
No. 14-14-00278-CR
In the FILED IN
Court of Appeals 14th COURT OF APPEALS
HOUSTON, TEXAS
For the
1/28/2015 6:57:20 AM
Fourteenth District of Texas CHRISTOPHER A. PRINE
At Houston Clerk
No. 1243451
In the 178th District Court
Of Harris County, Texas
CHADRICK CANARD JOHNSON
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 this case, and, in support thereof, presents the
following:
1. In the 178th District Court of Harris County, Texas, in cause number 1243451,
The State of Texas v. Chadrick Canard Johnson, Appellant was convicted of murder,
and was sentenced to forty five years in the Texas Department of Criminal Justice,
Correctional Institutions Division, on March 19, 2014.
2. A written notice of appeal was timely filed on March 19, 2014.
4. The State’s brief was due on January 22, 2015.
5. An extension of time in which to file the State’s brief is requested until January 30,
2015.
6. Three previous extensions of time have been requested by the State.
7. The facts relied upon to explain the need for this extension are:
The State’s Assistant District Attorney on appeal was mobilized to active duty
in the United States Navy on January 23, 2015. The original expected date of
this 1 year mobilization order was February 6, 2015, but was accelerated with
minimal notice. The requirement to relocate from Houston to Norfolk,
Virginia required a significant utilization of time previously intended to
complete this brief, and delayed the work on all assigned briefs. Temporary
relocation and mobilization requirements have been completed and work on
this brief has resumed. The State’s Assistant District Attorney on appeal will
submit this brief by the end of the current week.
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,
SETH GAGLIARDI
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 24073207
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been emailed and faxed
to the attorney for the Appellant on January 28, 2015:
Glenn Youngblood
5555 South Loop West, Suite 396
Bellaire, TX 77401
Phone: (713) 432-1013
Fax: (713) 574-3042
Email: glenlaw1@comcast.net
SETH GAGLIARDI
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 24073207
Date: January 28, 2015