Cary, Stacy Stine

PD-1341-14 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 4/24/2015 2:13:36 PM Accepted 4/24/2015 2:28:16 PM ABEL ACOSTA IN THE CLERK COURT OF COURT OF CRIMINAL APPEALS OF TEXAS ______________________________ No. PD-1341-14 _______________________________ April 24, 2015 STACY STINE CARY, Appellant v. THE STATE OF TEXAS, Appellee __________________________________________________________________ On Appeal from the Court of Appeals, Fifth District of Texas at Dallas Court of Appeals No. 05-12-01421-CR __________________________________________________________________ APPELLANT'S UNOPPOSED FIRST MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF Appellant Stacy Stine Cary respectfully moves for an extension of time to file her Appellant’s Brief by thirty (30) days. In support of this motion, she would respectfully show as follows: 1. The deadline for filing the Appellant’s Brief is April 24, 2015. 2. Appellant seeks a thirty-day extension. 3. An extension is necessary because of appellate counsel’s schedule since the time the PDR was granted, the complexity of the facts and issues, and the fact that the Fifth Court of Appeals has now issued an opinion in the related case of David Cary v. State of Texas, No. 05-13-01010-CR, in which the Court of Appeals Unopposed Motion for Extension of Time--Page 1 reversed the appellant’s conviction, and this opinion should be addressed in the initial brief. APPELLEE, THE STATE OF TEXAS, DOES NOT OPPOSE THIS REQUESTED EXTENSION. 4. No previous extension has been sought or granted. Respectfully submitted, ____/s/ John M. Helms____________ John M. Helms Texas Bar No. 09401001 BRODEN, MICKELSEN, HELMS & SNIPES, LLP 2600 State Street Dallas, Tx 75204 Tel: (469) 951-8496 Fax: (214) 720-9594 john@johnhelmslaw.com ATTORNEY FOR APPELLANT, STACY STINE CARY CERTIFICATE OF CONFERENCE Undersigned counsel has conferred with Joseph Corcoran, counsel for Appellee, the State of Texas, and the Appellee does not oppose this motion. ____/s/ John M. Helms____________ John M. Helms Unopposed Motion for Extension of Time--Page 2 CERTIFICATE OF SERVICE This certifies that a true and correct copy of this instrument has been served on counsel of record on April 23, 2015, as follows: Joseph Corcoran Assistant Attorney General P.O. Box 12548 Capitol Station Austin, TX 78711 * DELIVERED VIA E-MAIL * ____/s/ John M. Helms____________ John M. Helms Unopposed Motion for Extension of Time--Page 3