Felicity Burris v. State

ACCEPTED 01-14-00900-cr FIRST COURT OF APPEALS HOUSTON, TEXAS 4/13/2015 12:32:12 PM CHRISTOPHER PRINE CLERK No. 01-14-00900-CR In the FILED IN Court of Appeals 1st COURT OF APPEALS HOUSTON, TEXAS For the 4/13/2015 12:32:12 PM First Judicial District of Texas CHRISTOPHER A. PRINE At Houston Clerk ♦ No. 1344231 In the 180th District Court of Harris County, Texas ♦ FELICITY BURRIS Appellant v. THE STATE OF TEXAS Appellee ♦ STATE’S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE APPELLATE BRIEF ♦ TO THE HONORABLE COURT OF APPEALS OF TEXAS: COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.1(a) and 38.6(d) of the Texas Rules of Appellate Procedure, and files this motion for extension of time in which to file the State’s brief in this case, and, in support thereof, presents the following: 1. In the 180th District Court of Harris County, Texas, in The State of Texas v. Felicity Burris, Cause Numbers 1344231, appellant was charged with arson. 2. The court deferred appellant’s adjudication for five years. 3. The State’s brief is due on April 13, 2015. 5. An extension of time in which to file the State’s brief is requested until May 13, 2015. 6. No previous extension has been requested by the State. 7. The facts relied upon to explain the need for this extension are: a) The undersigned attorney was assigned this case on March 17, 2015. b) Since the undersigned attorney was assigned this case, the attorney finished writing the State’s briefs in the following cases: (1) Cause Number 14-14-00473-CR, Jimmy Earl Van-Cleave, Appellant v. The State of Texas, Appellee, which involves three points of error and three volumes of the reporter’s record; (2) Cause Number 01-14-00581-CR, Brodies E. Myles, Appellant v. The State of Texas, Appellee, which involves one points of error and four volumes of the reporter’s record; and (3) Cause Number 01-14-00421-CR, Eric Dewayne Small, Appellant v. The State of Texas, Appellee, which involves six points of error and eight volumes of the reporter’s record. c) The undersigned attorney was also preparing for oral argument in Cause Number 01-13-00931-CR, Melissa Dromgoole, Appellant v. The State of Texas, Appellee, that was held on April 8, 2015. d) The undersigned attorney is also currently engaged in the preparation of the State’s Brief in the following appellate cause numbers: (1) Cause Number 14-14-00874-CR, Charles Roberts, Appellant v. The State of Texas, Appellee, which involves three points of error and seven volumes of the reporter’s record; (2) Cause Number 01-14-00900-CR, James Lee Skinner, Appellant v. The State of Texas, Appellee, which involves three points of error and four volumes of the reporter’s record; and (3) Cause Number 14-14-00910-CR, Ex parte Erik Montes De Oca-Orozco, which involves two points of error and one volume of the reporter’s record. WHEREFORE, the State prays that this Court will grant an extension of time until May 13, 2015 in which to file the State’s brief in this case. Respectfully submitted, /s/ Carly Dessauer ________________________________________________________________________________________________________________________________________________________________________________________________________________________________ CARLY DESSAUER Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 State Bar No. 24069083 dessauer_carly@dao.hctx.net CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument will be served to appellant’s attorney on April 13, 2015 through TexFile: Tommy LaFon Attorney at Law 1244 Heights Blvd. Houston, Texas 77008 tomlafon@aol.com /s/ Carly Dessauer ________________________________________________________________________________________________________________________________________________________________________________________________________________________________ CARLY DESSAUER Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 State Bar No. 24069083 dessauer_carly@dao.hctx.net curry_alan@dao.hctx.net Date: April 13, 2015