ACCEPTED
14-14-00502-cr
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
2/16/2015 1:18:02 PM
CHRISTOPHER PRINE
CLERK
Nos. 14-14-00501-CR, 14-14-00502-CR, and 14-14-00503-CR
In the FILED IN
14th COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
For the 2/17/2015 8:28:00 AM
Fourteenth District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston
Nos. 1344552, 1344550, and 1344551
In the 180th Criminal District Court
Of Harris County, Texas
TIMOTHY HEARNE
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:
THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 10.1, 10.5(b) & 38.6(d),
moves for an extension of time within which to file its appellate brief. In support
of its motion, the State submits the following:
1. Appellant was charged with three counts of indecency with a child.
2. Appellant entered a plea of “not guilty” to all three allegations.
3. A jury found appellant guilty as charged in all three cases and later
assessed his punishment at confinement for 12 years per count
(sentence runs concurrently).
4. Appellant filed a written notice of appeal on June 11, 2014.
5. Appellant’s brief was filed December 1, 2014.
6. The State’s brief was due January 30, 2014.
7. The State seeks an extension until March 13, 2015, to file its brief.
8. The following facts are relied upon to show good cause for the
requested extension:
a. The undersigned attorney has filed 3 briefs in the last 30 days and
has 5 more briefs due in the next 30 days.
b. The State’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 until March 13, 2015.
Respectfully submitted,
/s/ Bridget Holloway
BRIDGET HOLLOWAY
Assistant District Attorney
Harris County, Texas
Harris County Criminal Justice Center
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
Texas Bar No. 24025227
holloway_bridget@dao.hctx.net
CERTIFICATE OF SERVICE
This certifies the undersigned attorney requested that a copy of this
document be served to appellant’s attorneys via TexFile at the following email on
February 16, 2015:
Tonya Rolland McLaughlin
Attorney at Law
Email: (not listed in brief, will use one, if any, on file with TexFile)
/s/ Bridget Holloway
BRIDGET HOLLOWAY
Assistant District Attorney
Harris County, Texas
Harris County Criminal Justice Center
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
Texas Bar No. 24025227
holloway_bridget@dao.hctx.net