FILED IN PD-1 341-1
COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEAL
AUSTIN, TEXA
July 27, 2015 Transmitted 7/27/2015 12:00:00 Af
Accepted 7/27/2015 8:13:45 Ar
ABELACOSTA, CLERK ABEL ACOST.
IN 1HE CLER
COURT OF COURT OF CRIMINAL APPEALS OF TEXAS
No. PD-1341-14
STACY STINE CARY, Appellant
v.
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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 REPLY BRIEF
Appellant Stacy Stine Cary respectfully moves for an extension of time to
file her Appellant's Brief by until August 14,2015. In support of this motion, she
would respectfully show as follows:
1. The deadline for filing the Appellant's Brief is July 27, 2015.
2. Appellant seeks an extension of time of 18 days, until August 14,
2015.
3. An extension is necessary because of appellate counsel's schedule and
the complexity of the issues. Appellant's counsel finished a jury trial in
Greenville, Texas during the week of July 13, 2015, and he has been trying to
Unopposed Motion for Extension of Time—Page 1
catch up with other matters since then. Appellant's counsel has a hearing in
federal court in McAllen, Texas on Monday, July 27, 2015 and then is scheduled to
take his eleven-year-old special needs son to Europe and will return on the evening
of August 8, 2015. APPELLEE, THE STATE OF TEXAS, DOES NOT
OPPOSE THIS REQUESTED EXTENSION.
4. No previous extension has been sought or granted.
Respectfully submitted,
Isi 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 July 25, 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