ACCEPTED
01-14-00232-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
1/26/2015 1:34:15 PM
CHRISTOPHER PRINE
CLERK
No. 1-14-00232-CR
In the
Court of Appeals FILED IN
1st COURT OF APPEALS
For the HOUSTON, TEXAS
First District of Texas 1/26/2015 1:34:15 PM
At Houston CHRISTOPHER A. PRINE
Clerk
No. 2338052
th
In the 338 Judicial District Court
Of Harris County, Texas
ARTURO CHAVEZ Appellant
V.
THE STATE OF TEXAS
Appellee
STATE’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE COURT OF APPEALS:
THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 2 & 10.5, moves for
an extension of time in which to file its appellate brief and in its motion, would
show the Court the following:
1. The appellant was charged with murder, convicted, and sentenced to
incarceration for life on November 22, 2013 (CR – 6, 609-610).
Appellant filed notice of appeal on February 14, 2014 (CR-616).
2. The State’s brief was due on January 12, 2015. The State hereby
requests a 30-day extension for the filing of the State’s brief.
3. The following facts are relied upon to show good cause for an extension
of time to allow the State to file its brief:
a. The State did not receive a copy of appellants brief until Friday,
January 23, 2015, and the undersigned attorney was not assigned
this case until January 26, 2015.
b. The undersigned attorney just started work at the Harris County
District Attorney’s Office and today is her first day. It will take
some time to get acquainted with the procedures of the office the
filing of briefs.
c. The undersigned attorney has also been assigned four other briefs
as of today, two of which are also overdue:
(1) Louis Charles Kirk v. The State of Texas
No. 14-14-00168-CR
Brief filed December 4, 2014
(2) Ronald Robinson v. The State of Texas
No. 1-14-00656-CR
Brief filed January 12, 2015
(3) Norman Andrew Puckett v. The State of Texas
No. 14-14-00313-CR
Brief filed January 6, 2015
(4) Maatthew Vincent Woodard v. The State of Texas
No. 14-13-00609-CR
Brief filed December 14, 2015
WHEREFORE, the State prays that this Court will grant the requested extension.
Respectfully submitted,
/s/ Kimberly Stelter
KIMBERLY STELTER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
Stelter_Kimberly@dao.hctx.net
TBC No. 19141400
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served by
efile.txcourts.gov to:
Matt Hennessy
Attorney at Law
1018 Preston, 7th Floor
Houston, Texas 77002
matt@deguerin.com
/s/ Kimberly Stelter
KIMBERLY STELTER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
Stelter_Kimberly@dao.hctx.net
TBC No. 19141400
(713) 755-5826
TBC No. 796910
Date: January 26, 2015