ACCEPTED
01-13-00805-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/10/2015 9:44:47 AM
CHRISTOPHER PRINE
CLERK
IN THE
FIRST COURT OF APPEALS
OF TEXAS FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
RODNEY CARNELL MAYS § 4/10/2015 9:44:47 AM
§ CHRISTOPHER A. PRINE
VS. § CASE NO. 01-13-00805-CR
Clerk
§
THE STATE OF TEXAS §
MOTION TO EXTEND TIME WITHIN WHICH TO FILE APPELLATE
BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
NOW COMES, RODNEY CARNELL MAYS, appellant in the above-styled
and numbered cause, by and through his attorney of record, Daucie Schindler, and
respectfully moves the Court for an extension of time within which to file the
appellate brief, and for cause would show the Court as follows:
I.
Mr. Mays was charged with the misdemeanor offense of assault on a family
member. On September 3, 2013, Mr. Mays entered a plea of not guilty and proceeded
to trial. The judge found Mr. Mays guilty as charged. Mr. Mays’ punishment was
assessed by agreement at fifty-six (56) days in the Harris County jail.
II.
Mr. Mays filed timely notice of appeal. Undersigned counsel, of The Harris
County Public Defender’s Office was appointed to represent Mr. Mays on October 3,
2014.
III.
The appellate brief is due to be filed with the Court on or before April 10,
2015. One previous extension has been requested.
IV.
Undersigned counsel has been working simultaneously on appeal in State v.
Briones, State v. Snavely, State v. Tavarez, State v. Fletcher, State v. Marks, State v.
Umanzor, and State v. Phillips. Counsel is diligently working on the brief in this case,
but requests additional time having only just recognized a meritorious issue and
needing to confer with the client.
V.
This request is made not to delay the proceedings, but to ensure that Mr. Mays
is adequately represented.
WHEREFORE, PREMISES CONSIDERED, Mr. Mays respectfully prays that this
motion be granted and that the Court permits an extension of time until May 11,
2015, to file the appellate brief.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Daucie Schindler
DAUCIE SCHINDLER
Assistant Public Defender
Harris County Texas
1201 Franklin, 13th Floor
Houston Texas 77002
(713) 368-0016
(713) 368-9278 (Fax)
Daucie.Schindler@pdo.hctx.net
Attorney for Appellant,
RODNEY CARNELL MAYS
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Appellant’s
Motion to Extend Time within Which to File Appellate Brief was e-mailed to the
Appellate Division of the Harris County District Attorney’s Office on this 10th day of
April, 2015.
/s/ Daucie Schindler
DAUCIE SCHINDLER