ACCEPTED
01-15-00185-cr
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/19/2015 10:13:00 AM
CHRISTOPHER PRINE
CLERK
IN THE
FIRST COURT OF APPEALS
OF TEXAS FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
JASON SNAVELY § 6/19/2015 10:13:00 AM
§ CHRISTOPHER A. PRINE
VS. § CASE NO. 01-15-00185-CR
Clerk
§
THE STATE OF TEXAS §
MOTION TO EXTEND TIME WITHIN WHICH TO FILE APPELLATE
BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
NOW COMES, JASON SNAVELY, appellant in the above-styled and
numbered cause, by and through his attorney of record, Daucie Schindler, and
respectfully moves the Court for an extension of time within which to file the
appellate brief, and for cause would show the Court as follows:
I.
Mr. Snavely was charged with the felony offense of aggravated assault of a
household member. On February 14, 2014, Mr. Snavely was convicted as charged
and sentenced by the jury to fifty-five (55) years imprisonment in the Institutional
Division of Texas Department of Criminal Justice.
II.
Mr. Snavely filed timely notice of appeal. Undersigned counsel, of The Harris
County Public Defender’s Office was appointed to represent Mr. Snavely on February
19, 2015.
III.
The appellate brief is due to be filed with the Court on or before June 19, 2015.
One previous extension has been requested.
IV.
Undersigned counsel has been working simultaneously on appeal in State v.
Earvin, State v. Wiggins, State v. Tavarez, State v. Phillips, State v. Means, State v.
Umanzor, and State v. Mays. Counsel is diligently working on the brief in this case,
but requests additional time for the supplementation of the record and to research
and confer with the client.
V.
This request is made not to delay the proceedings, but to ensure that Mr.
Snavely is adequately represented.
WHEREFORE, PREMISES CONSIDERED, Mr. Snavely respectfully prays that
this motion be granted and that the Court permits an extension of time until July 20,
2015, to file the appellate brief.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Daucie Schindler
DAUCIE SCHINDLER
Assistant Public Defender
Harris County Texas
1201 Franklin, 13th Floor
Houston Texas 77002
(713) 368-0016
(713) 368-9278 (Fax)
Daucie.Schindler@pdo.hctx.net
Attorney for Appellant,
JASON SNAVELY
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Appellant’s
Motion to Extend Time within Which to File Appellate Brief was e-mailed to the
Appellate Division of the Harris County District Attorney’s Office on this 19th day of
June, 2015.
/s/ Daucie Schindler
DAUCIE SCHINDLER