PD-0162-14
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
March 26, 2015 Transmitted 3/26/2015 3:49:54 PM
Accepted 3/26/2015 3:58:48 PM
ABEL ACOSTA
No. PD-0162-14 CLERK
BRANDON SCOTT BLASDELL § IN THE COURT OF
§
V. § CRIMINAL APPEALS
§
THE STATE OF TEXAS § AT AUSTIN, TEXAS
____________________________________________________
STATE'S MOTION FOR
EXTENSION OF TIME TO FILE BRIEF
____________________________________________________
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW the State of Texas, by the undersigned assistant district
attorney, and moves the Court for an extension of time to file its appellate brief in the
above-captioned case. The State would respectfully show the Court the following:
1. The appellant was convicted of the offense of aggravated robbery. His
punishment was assessed at imprisonment for 30 years.
2. This Court granted the appellant’s petition for discretionary review and the
appellant’s brief was filed on February 24, 2015.
3. The State’s brief is due to be filed in this Court on March 26, 2015.
4. The State has not previously requested an extension of time to file its brief.
5. The State hereby requests a thirty-day extension of time to file its brief,
until April 24, 2015.
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9. Good cause exists for the requested extension of time, for the following
reasons:
In the past 30 days, the undersigned counsel for the State has
been required to prepare and file several written responses, including
the State’s appellate brief in the Lauro Grimaldo Rincon v. The State of
Texas, Case No. 14-14-00535-CR; the State’s appellate brief in
Veronica Gonzalez v. The State of Texas, Case No. 09-14-00322-CR;
the State’s answer to application for post-conviction writ of habeas
corpus and proposed findings of fact and conclusions of law in Ex parte
Kyle Clayton Ellisor, Case No. 11-02-01557-CR-(1); and the State’s
answer to application for post-conviction writ of habeas corpus and
proposed findings of fact and conclusions of law in Ex parte Jermond
Dewayne Thompson, Case No. 13-05-05262-CR-(1).
THEREFORE, the State requests an extension of time to file its response until
April 24, 2015, in this case.
Respectfully submitted,
BRETT W. LIGON
District Attorney
Montgomery County, Texas
BRENT CHAPELL
Assistant District Attorney
Montgomery County, Texas
S.B.T. No. 24087284
207 W. Phillips, Second Floor
Conroe, Texas 77301
(936) 539-7800
(936) 788-8395 (fax)
brent.chapell@mctx.org
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing motion was
mailed to the appellant, at the following address, on the date of the filing of the
original with the Clerk of this Court:
Mr. Jeremy S. Dishongh
Attorney at Law
332 N. Main
Conroe, Texas 77301
BRENT CHAPELL
Assistant District Attorney
Montgomery County, Texas
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Blasdell, Brandon Scott
Combined Opinion