ACCEPTED
01-14-00721-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/20/2015 2:52:44 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00721-CR FILED IN
1st COURT OF APPEALS
IN THE COURT OF APPEALS FOR THE HOUSTON, TEXAS
FIRST DISTRICT, SITTING AT 3/20/2015 2:52:44 PM
HOUSTON CHRISTOPHER A. PRINE
Clerk
____________
JAMES JORDAN, APPELLANT
v.
THE STATE OF TEXAS, APPELLEE
STATE=S MOTION FOR EXTENSION OF TIME
TO THE HONORABLE COURTOF APPEALS:
COMES NOW, THE STATE OF TEXAS, by and through the undersigned
Assistant District Attorney, and moves this Court to grant an extension of time for
the State to file its brief in the above styled and numbered cause. In support thereof,
the State would show the following:
1. The Clerk=s Record was filed in this case on September 10, 2014.
Approximately seven supplemental Clerk’s Records were filed, with
the latest being filed on December 18, 2014.
2. The Reporter=s Record was filed in this case on October 20, 2014.
3. The State=s brief in this cause was due on March 9, 2015. The State
has not filed any previous requests for extension of time. The
Appellant requested and was granted two extensions of time.
4. The State’s attorney assigned to this case currently has many other
pending matters including several pending appeals and writs, including
a writ in a death penalty case, Andrus v. State. Further, the State’s
attorney assigned to this case had an absence from the office during the
period that this brief was due in relation to the birth of his second child.
5. The State would request that the deadline for the State’s brief in this
cause be extended 60 (sixty) days.
6. This extension is not sought for the sole purpose of delay.
WHEREFORE, PREMISES CONSIDERED, the State prays that this
Honorable Court grant this motion and extend the deadline for filing the State=s brief
in this case.
Respectfully submitted,
/s/ Jason Bennyhoff
JASON BENNYHOFF
ASST. DISTRICT ATTORNEY
Fort Bend County, Texas
State Bar Number 24050277
1422 Eugene Heimann Cir.
Richmond, Texas 77469
Phone: (281) 238-3352
Fax: (281) 238-3366
CERTIFICATE OF SERVICE
I, Jason Bennyhoff, do hereby certify that a true and correct copy of the
foregoing Motion was sent to counsel for the Appellant on March 20, 2015, via
electronic mail through the EFile Texas electronic filing system.
/s/ Jason Bennyhoff
Jason Bennyhoff