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IN THE ^
COURT OF COURT OF CRIMINAL APPEALS OF TEXAS
No. PD-1341-14
FILED IN
COURT OF CRIMINAL APPEALS
STACY STINE CARY, Appellant May 11 2015
ABEL ACOSTA, CLERK
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 MOTION TO EXTEND
TIME TO FILE APPELLANT'S BRIEF BY FOUR DAYS
Appellant Stacy Stine Cary respectfully moves for an extension of time to
file her Appellant's Brief by four (4) days. In support of this motion, she would
respectfully show as follows:
1. The deadline for filing the Appellant's Brief is Monday, May 11,
2015.
2. Appellant seeks a four-day extension until Friday, May 15, 2015.
3. An extension is necessary because of appellate counsel's schedule, 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-
Unopposed Motion for Extension of Time—Page 1
13-01010-CR. Specifically, in the last two weeks, appellate counsel has had to
prepare for/attend multiple contested evidentiary hearings and has a highly
contested sentencing in federal court that will involve both fact and expert
testimony and out-of-town witnesses. In the David Cary case, the Dallas Court of
Appeals reversed the appellant's conviction, and this opinion needs to be addressed
in the initial brief. The four-day extension that counsel has requested will also
allow enough time for the Appellant and her husband to review the appellant's
brief and to give input to counsel concerning the trial record. APPELLEE, THE
STATE OF TEXAS, DOES NOT OPPOSE THIS REQUESTED
EXTENSION.
4. Ms. Cary previously made an unopposed request for an extension of
thirty (30) days, but the Court granted an extension of seventeen (17) days. Ms.
Cary will not seek afurther extension oftimefor this appellant's brief ifthis
request is granted.
Unopposed Motion for Extension of Time—Page 2
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
CERTIFICATE OF SERVICE
This certifies that a true and correct copy of this instrument has been served
on counsel of record on May 11, 2015, as follows:
Joseph Corcoran
Assistant Attorney General
P.O.Box 12548
Capitol Station
Austin, TX 78711
* DELIVERED VIA E-MAIL *
Isl John M. Helms
John M. Helms
Unopposed Motion for Extension of Time—Page 3
Cary, Stacy Stine
Combined Opinion