ACCEPTED
14-15-00126-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
4/20/2015 4:08:20 PM
CHRISTOPHER PRINE
CLERK
No. 14-15-00126-CR
No. 14-15-00127-CR
No. 14-15-00128-CR FILED IN
No. 14-15-00129-CR 14th COURT OF APPEALS
HOUSTON, TEXAS
In the 4/20/2015 4:08:20 PM
CHRISTOPHER A. PRINE
Court of Appeals Clerk
For the
Fourteenth District of Texas
At Houston
No. 1405266
No. 1405276
No. 1428986
No. 1428987
In the 232nd District Court
Harris County, Texas
JOSEPH HOENINGHAUS
Appellant
v.
THE STATE OF TEXAS
Appellee
STATE’S MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE APPELLATE BRIEF
TO THE HONORABLE COURT OF APPEALS OF TEXAS:
COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.5(b)(1) and
38.6(d) of the Texas Rules of Appellate Procedure, and files this motion for extension of
time in which to file the State’s brief in this case, and, in support thereof, presents the
following:
1. In the 232nd District Court of Harris County, Texas, in cause number 1405266,
on May 22, 2014, Appellant was convicted in The State of Texas v. Joseph Hoeninghaus.
2. For the offense of burglary of a habitation, his punishment was assessed at nine
years in prison.
3. In the 232nd District Court of Harris County, Texas, in cause number 1405276,
on May 22, 2014, Appellant was convicted in The State of Texas v. Joseph Hoeninghaus.
4. For the offense of possession of a controlled substance, his punishment was
assessed at nine years in prison.
5. In the 232nd District Court of Harris County, Texas, in cause number 1428986,
on May 22, 2014, Appellant was convicted in The State of Texas v. Joseph Hoeninghaus.
6. For the offense of burglary of a habitation, his punishment was assessed at nine
years in prison.
7. In the 232nd District Court of Harris County, Texas, in cause number 1428987,
on May 22, 2014, Appellant was convicted in The State of Texas v. Joseph Hoeninghaus.
8. For the offense of unauthorized use of a vehicle, his punishment was assessed at
nine years in prison.
9. Written notices of appeal were filed on February 2, 2015.
10. Appellant’s brief was filed with this Court on March 11, 2015.
11. The State’s brief was due to be filed with this Court on April 10, 2015.
12. An extension of time in which to file the State’s brief is requested until April 21,
2015.
13. No previous extensions have been granted to the State.
14. The facts relied upon to explain the need for this extension are:
The State’s brief in this case is being prepared by the Chief of the Appellate
Division. He has numerous other duties in that position. Therefore, additional
time has been necessary in order to prepare the State’s brief.
WHEREFORE, the State prays that this Court will grant an extension of time until
April 21, 2015, in which to file the State’s brief in these cases.
Respectfully submitted,
/s/ Alan Curry
ALAN CURRY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 05263700
curry_alan@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been mailed to the
appellant at the following addresses on April 20, 2015:
Joseph Hoeninghaus
SPN # 02425262
Cell # 2G4
701 North San Jacinto
Houston, Texas 77002
/s/ Alan Curry
ALAN CURRY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 05263700
curry_alan@dao.hctx.net
Date: April 20, 2015