ACCEPTED
01-14-00593-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
2/25/2015 4:02:29 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00593-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
for the 2/25/2015 4:02:29 PM
First District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston
No. 1344348
In the 338th District Court
Of Harris County, Texas
TONY ESCOBAR
Appellant
v.
THE STATE OF TEXAS
Appellee
STATE’S MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE AN APPELLATE BRIEF
TO THE HONORABLE COURT OF APPEALS OF TEXAS:
COMES NOW THE STATE OF TEXAS, in accordance with Rules
10.5(b)(1) and 38.6(d) of the Texas Rules of Appellate Procedure, and files this
motion for an extension of time in which to file the State’s brief in this cause, and,
in support thereof, presents the following:
1. Appellant was convicted of capital murder and sentenced to life
imprisonment in the Institutional Division of the Texas Department of
Criminal Justice.
2. Appellant filed a written notice of appeal on July 3, 2014.
3. The State’s brief was due on February 25, 2015.
4. An extension of time in which to file the State’s brief is requested until
March 27, 2015. No previous extensions have been granted.
5. The following facts are relied upon to show good cause for the requested
extension:
i. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. 01-14-00422-CR, Benjamin
Maurine Sadler, Appellant v. The State of Texas, Appellee,
which was filed on January 29, 2015.
ii. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause Nos. 01-14-00072-CR & 01-14-
00073-CR, Larry Wayne Richard, Appellant v. The State of
Texas, Appellee, which was filed on February 9, 2015.
iii. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. 01-12-00551-CR, Lox Gorme,
Appellant v. The State of Texas, Appellee, which was filed on
February 13, 2015.
iv. The undersigned attorney is currently engaged engaged in the
preparation of the State’s Brief in Cause No. 01-14-00392-CR,
Chance Roach, Appellant v. The State of Texas, Appellee.
WHEREFORE, the State prays that this Court will grant an additional
extension of time until March 27, 2015 in which to file the State’s brief in this
cause.
Respectfully submitted,
/s/ Heather A. Hudson
HEATHER A. HUDSON
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24058991
hudson_heather@dao.hctx.net
curry_alan@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been submitted
for service by e-filing to the following address:
Wayne T. Hill
4615 Southwest Freeway, Suite 600
Houston, Texas 77027
Tel: (713) 623-8312
Fax: (713) 626-0182
wthlaw@aol.com
/s/ Heather A. Hudson
HEATHER A. HUDSON
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24058991
Date: February 25, 2015