PD-1341-1
COURT OF CRIMINAL APPEAL
AUSTIN, TEXA
Transmitted 8/11/2015 5:45:39 PI
Accepted 8/12/2015 10:07:55 Al
IN THE ABELAc?er
COURT OF COURT OF CRIMINAL APPEALS OF TEXAS
No. PD-1341-14 filed IN
COURT OF CRIMINAL APPEALS
August 12, 2015
STACY STINE CARY, Appellant abelacosta, clerk
THE STATE OF TEXAS, Appellee XPC
On Appeal from the Court of Appeals, Fifth District of Texas at Dallas
Court of Appeals No. 05-12-01421-CR
APPELLANT'S UNOPPOSED MOTION
TO EXTEND TIME TO FILE REPLY BRIEF BY TWO BUSINESS DAYS
Appellant Stacy Stine Cary respectfully moves for an extension of time to
file her Appellant's Brief by two business days, until August 18, 2015. In support
of this motion, she would respectfully show as follows:
1. The deadline for filing the Appellant's Brief is Friday, August 14,
2015.
2. Appellant seeks an extension of time of two business days, until
Tuesday, August 18, 2015.
3. An extension is necessary because of appellate counsel's schedule and
the complexity of the issues. Appellant's counsel has an evidentiary hearing in a
Unopposed Motion for Extension of Time—Page 1
criminal case on Thursday, August 13, 2015 and an all-day deposition in a civil
case on Friday, August 14, 2015, that cannot be moved. Appellee also has a likely
pretrial conference for a criminal trial in Hunt County, Texas on Monday, August
17, 2015, for a likely trial on August 24, 2015, for which he is preparing.
APPELLEE, THE STATE OF TEXAS, DOES NOT OPPOSE THIS
REQUESTED EXTENSION.
4. The Court has previously extended the time for this reply brief by 18
days. If granted, Ms. Cary will not request a further extension.
Respectfully submitted,
/s/ John M. Helms
John M. Helms
Texas Bar No. 09401001
BRODEN, MICKELSEN, HELMS &
SNIPES, LLP
2600 State Street
Dallas, Tx 75204
Tel: (469)951-8496
Fax:(214)720-9594
john@j ohnhelmslaw.com
ATTORNEY FOR APPELLANT,
STACY STINE CARY
CERTIFICATE OF CONFERENCE
Undersigned counsel has conferred with Joseph Corcoran, counsel for
Appellee, the State of Texas, and the Appellee does not oppose this motion.
Unopposed Motion for Extension of Time—Page 2
/s/ John M. Helms
John M. Helms
CERTIFICATE OF SERVICE
This certifies that a true and correct copy of this instrument has been served
on counsel of record on August 11, 2015, as follows:
Joseph Corcoran
Assistant Attorney General
P.O. Box 12548
Capitol Station
Austin, TX 78711
* DELIVERED VIA E-MAIL *
/s/ John M. Helms
John M. Helms
Unopposed Motion for Extension of Time—Page 3