PD-0022-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 8/11/2015 1:23:59 PM
Accepted 8/11/2015 1:28:43 PM
August 11, 2015 No. PD-0019-15 ABEL ACOSTA
CLERK
No. PD-0020-15
No. PD-0021-15
No. PD-0022-15
___________________________________________________
IN THE TEXAS COURT OF CRIMINAL APPEALS
___________________________________________________
STATE OF TEXAS, APPELLANT
v.
ALBERT G. HILL III, APPELLEE
___________________________________________________
On Discretionary Review from
Nos. 05-13-00421-CR-180, 05-13-00423-CR,
05-13-00424-CR, and 05-13-00425-CR from the
Fifth District Court of Appeals at Dallas
___________________________________________________
UNOPPOSED MOTION TO EXTEND TIME TO FILE
APPELLANT’S OPENING BRIEF
___________________________________________________
Charles “Chad” Baruch
Texas Bar Number 01864300
LAW OFFICE OF CHAD BARUCH
3201 Main Street
Rowlett, Texas 75088
Telephone: (972) 412-7192
Facsimile: (972) 412-4028
E-mail: baruchesq@aol.com
District Attorney Pro Tem of Dallas County,
Texas
TO THE HONORABLE TEXAS COURT OF CRIMINAL APPEALS:
1. The State’s opening brief is due on August 26, 2015. This is the
State’s first extension request for its opening brief.
2. The Dallas County District Attorney’s Office has recused itself
from this case. The undersigned counsel was appointed District Attorney
Pro Tem on March 12, 2015.
3. In addition to his ordinary workload, the undersigned counsel
has had, and still has, several briefs due during the time period since
receiving Mr. Hill’s brief in this case, including: (1) Petitioners’ Reply Brief
on the Merits in a complex home-schooling case in the Supreme Court of
Texas (No. 14-0732), (2) Appellees’ Brief in the Amarillo Court of Appeals
(No. 07-15-00128-CV), (3) Appellees’ Brief in the Dallas Court of Appeals
(No. 05-15-00529-CV), (4) a reply in support of a rehearing motion in the
Supreme Court of Texas (No. 15-0120), and (5) Appellants’ Reply Brief in
the El Paso Court of Appeals (No. 08-11-00182-CV). As result, counsel
cannot complete the State’s brief by August 26, 2015.
4. The State of Texas therefore seeks a 30-day extension of time to
file its opening brief, to September 25, 2015.
5. Appellee does not oppose this motion.
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Respectfully submitted,
/s/Charles “Chad” Baruch
THE LAW OFFICE OF CHAD BARUCH
3201 Main Street
Rowlett, Texas 75088
Telephone: (972) 412-7192
Facsimile: (972) 412-4028
Email: baruchesq@aol.com
Counsel for State of Texas
CERTIFICATE OF COMPLIANCE
The undersigned certifies that that this motion was prepared using
Microsoft Word for Mac, and that the software program word count tool
indicates that this motion contains a total of 181 words exclusive of the cover,
signature block, and certificates.
/s/Charles “Chad” Baruch
CERTIFICATE OF CONFERENCE
The undersigned certifies that he conferred with Michael Mowla, lead
counsel for Mr. Hill, who stated he does not oppose this request.
/s/Charles “Chad” Baruch
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CERTIFICATE OF SERVICE
The undersigned certifies a true and correct copy of this instrument
was served this 11th day of August, 2015, upon the following counsel of
record:
Michael Mowla
445 East FM 1382, Suite 3-718
Cedar Hill, Texas 75104
michael@mowlalaw.com
/s/Charles “Chad” Baruch
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