ACCEPTED
14-13-01078-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
2/20/2015 6:12:01 PM
CHRISTOPHER PRINE
CLERK
Cause Nos. 14-13-01077-CR and 14-13-01078-CR
IN THE COURT OF APPEALS FILED IN
14th COURT OF APPEALS
FOR THE HOUSTON, TEXAS
FOURTEENTH JUDICIAL DISTRICT OF TEXAS
2/20/2015 6:12:01 PM
AT HOUSTON CHRISTOPHER A. PRINE
Clerk
JACQUALIEN GRANT,
Appellant
v.
THE STATE OF TEXAS,
Appellee.
Appeal from Cause Nos. 13806096 and 1386097
In the 185th District Court of
Harris County, Texas
______________________________________________
APPELLANT’S MOTION FOR EXTENSION OF TIME
TO FILE SUPPLEMENTAL BRIEF
_______________________________________________
TO THE HONORABLE JUSTICES OF THE FOURTEENTH DISTRICT
COURT OF APPEALS:
Appellant, JACQUALIEN GRANT, by and through his Counsel of Record,
CARMEN M. ROE, files this Motion to Extend Time to File Supplemental Brief For
Appellant and in support shows this Court the following:
I.
Appellant was convicted in the 185th District Court of Harris County, Texas, in
Cause No. 1386906 and 1386097, for the offense of aggravated kidnapping and sexual
assault. Punishment was assessed at life in the Texas Department of Criminal Justice
Institutional Division.
II.
The Appellant’s brief was filed April 15, 2014. The State’s brief was filed June
18, 2014. Oral Argument was granted and set for December 18, 2014. On December 12,
2014, this Court issued a letter-ordering Appellant to file a response in regards to
Appellant’s conviction in Cause No. 14-13-01087-CR. Thereafter, Appellant filed a
motion to postpone submission and extend time to file an Supplemental Brief. This
Court granted two motions to extend time and Appellant’s Supplemental Brief was now
due February 13, 2015.
III.
Appellant now requests a final extension of time until February 20, 2015 to file its
Supplemental Brief and attaches it to this motion. Counsel requests the additional
extension of because Counsel is a solo-practitioner with the following briefs due: United
States v. Gonzalo Mosso-De Jesus and State v. Frank Distefano. Counsel completed a
motion for new trial due in State v. Mashood Uddin, a petition for discretionary review
due in State v. Zachary Hernandez, and has oral argument scheduled in State v. Marcos
Flores. For these reasons, counsel has been unable to submit the Appellant’s Brief on
the due date and hereby requests an extension of time. For all these reasons, Counsel is
requesting a final extension of time and attaches its supplemental brief to this filing.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable
Court extend the time for filing Appellant’s Supplemental Brief in this cause until
February 20, 2015.
RESPECTFULLY SUBMITTED,
/s/ Carmen M. Roe
_________________________________
CARMEN M. ROE
LAW OFFICE OF CARMEN M. ROE
SBN: 24048773
440 Louisiana, Suite 900
Houston, Texas 77002
713.236.7755 Phone
713.236.7756 Fax
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing was served to the
Harris County District Attorney, Appellate Division, 1201 Franklin Street, Houston,
Texas 77002, on February 20, 2015.
/s/ Carmen M. Roe
_____________________________
CARMEN M. ROE