ACCEPTED
01-14-00593-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/27/2015 2:31:55 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00593-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
for the 4/27/2015 2:31:55 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 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. 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 April 27, 2015.
4. A final extension of time in which to file the State’s brief is requested until
May 12, 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. 01-14-00486-CR, Mark
Castellano, Appellant v. The State of Texas, Appellee, which
was filed on March 31, 2015.
ii. 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 an additional
extension of time until May 12, 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: April 27, 2015