AP-77,051
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 5/12/2015 3:18:46 PM
May 12, 2015 Accepted 5/12/2015 3:21:45 PM
No. AP-77,051 ABEL ACOSTA
CLERK
In the
Texas Court of Criminal Appeals
at Austin
No. 0475122
In the 228th District Court
Harris County, Texas
WARREN DARRELL RIVERS
Appellant
V.
THE STATE OF TEXAS
Appellee
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE APPELLATE BRIEF
TO THE HONORABLE COURT OF APPEALS:
APPELLANT, pursuant to TEX. R. APP. P. 10.1, 10.5(b) and 38.6(d), moves for an
extension of time within which to file its appellate brief. In support of its motion, appellant
submits the following:
1. Appellant was charged with capital murder.
2. A jury convicted appellant of the charged offense. In accordance with the
jury’s answers to the special issues, the court sentenced appellant to death on
November 18, 2014.
3. Notice of appeal was filed on November 18, 2014.
4. Appellant’s brief is due on May 18, 2015.
5. Appellant seeks an extension to file his brief until November 18, 2014.
6. The following facts are relied upon to show good cause for the requested
extension:
a. The record in this case is voluminous, consisting of 32 volumes and many
exhibits.
b. Appellant’s motion is not for purposes of delay, but so that justice may be
done.
WHEREFORE, the State prays that this Court will grant the requested extension.
Respectfully submitted,
/s/PATRICK MCCANN
PATRICK MCCANN
SBN 00792680
MANDY MILLER
SPN 24055561
Attorneys for appellant
909 Texas Ave., Ste. 205
Houston, TX 77022
PHONE (713) 223-3805
FAX (281) 667-3352
writlawyer@justice.com
mandy@mandymillerlegal.com
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CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been delivered via
electronic mail to the following address:
Alan Curry
curry_alan@dao.hctx.net
/s/PATRICK MCCANN
PATRICK MCCANN
SBN 00792680
MANDY MILLER
SPN 24055561
Attorneys for appellant
909 Texas Ave., Ste. 205
Houston, TX 77022
PHONE (713) 223-3805
FAX (281) 667-3352
writlawyer@justice.com
mandy@mandymillerlegal.com
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