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