ACCEPTED
01-14-00392-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
1/30/2015 3:41:11 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00392-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
for the 1/30/2015 3:41:11 PM
First District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston
No. 1394753
In the 185th District Court
Of Harris County, Texas
CHANCE ROACH
Appellant
v.
THE STATE OF TEXAS
Appellee
STATE’S SECOND MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE AN 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 an extension of time in which to file the State’s brief in this cause, and,
in support thereof, presents the following:
1. On April 25, 2014, a jury convicted appellant of aggravated assault with a
deadly weapon and sentenced him to 20 years in the Institutional Division of
the Texas Department of Criminal Justice and a $10,000 fine.
2. Appellant filed a timely written notice of appeal on April 25, 2014.
3. The State’s brief was due on January 30, 2015.
4. An extension of time in which to file the State’s brief is requested until
March 2, 2015.
5. The following facts are relied upon to show good cause for the requested
extension:
i. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. 14-14-00139-CR, Isaac Smith,
Appellant v. The State of Texas, Appellee.
ii. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. 01-14-00422-CR, Benjamin
Maurine Sadler, Appellant v. The State of Texas, Appellee.
iii. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. 01-12-01175-CR, Mark
Rascoe, Appellant v. The State of Texas, Appellee.
iv. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause Nos. 01-14-00072-CR & 01-14-
00073-CR, Larry Wayne Richard, Appellant v. The State of
Texas, Appellee.
WHEREFORE, the State prays that this Court will grant an additional
extension of time until March 2, 2015 in which to file the State’s brief in this
cause.
Respectfully submitted,
/s/ Heather A. Hudson
HEATHER A. HUDSON
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24058991
hudson_heather@dao.hctx.net
curry_alan@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been submitted
for service by e-filing to the following address:
Sarah V. Wood
Assistant Public Defender
1201 Franklin, 13th Floor
Houston, Texas 77002
Tel: (713) 368-0016
Fax: (713) 368-9278
Sarah.Wood@pdo.hctx.net
/s/ Heather A. Hudson
HEATHER A. HUDSON
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24058991
Date: January 30, 2015