ACCEPTED
01-14-00486-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/17/2015 9:18:51 AM
CHRISTOPHER PRINE
CLERK
No. 01-14-00486-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
for the 3/17/2015 9:18:51 AM
First District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston
No. 1363068
In the 184th District Court
Of Harris County, Texas
MARK AUGUSTIN CASTELLANO
Appellant
v.
THE STATE OF TEXAS
Appellee
STATE’S THIRD 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. On June 6, 2014, appellant was convicted by a jury of murder and sentenced
to 27 years in the Institutional Division of the Texas Department of Criminal
Justice.
2. Appellant filed a timely written notice of appeal.
3. The State’s Brief was due on March 16, 2015.
4. An extension of time in which to file the State’s Brief is requested until
March 31, 2015.
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. 01-14-00392-CR, Chance
Roach, Appellant v. The State of Texas, Appellee, which was
filed on March 3, 2015.
ii. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. 01-14-00593-CR, Tony
Escobar, Appellant v. The State of Texas, Appellee, which is
due to be filed on March 27, 2015.
iii. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. AP-77039, Jeffrey Keith
Prevost, Appellant v. The State of Texas, Appellee, which is due
to be filed on June 8, 2015.
WHEREFORE, the State prays that this Court will grant a final extension of
time until March 31, 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:
Jani Maselli Wood
Assistant Public Defender
1201 Franklin, 13th Floor
Houston, Texas 77002
Tel: (713) 368-0016
Fax: (713) 368-9278
Jani.Maselli@pdo.hctx.net
/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: March 17, 2015