Ever Rodriguez Gonzalez v. State

ACCEPTED 01-15-00395-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 8/13/2015 9:26:26 AM CHRISTOPHER PRINE CLERK No. 01-15-00395-CR FILED IN EVER RODRIGUEZ GONZALEZ X 1st OF IN THE COURT COURT OF APPEALS APPEALS HOUSTON, TEXAS X 8/13/2015 9:26:26 AM X CHRISTOPHER A. PRINE VS. X FOR THE STATE OFClerk TEXAS X X THE STATE OF TEXAS X 1ST JUDICIAL DISTRICT MOTION FOR FIRST EXTENSION OF TIME TO FILE APPELLANT’S BRIEF COMES NOW, EVER RODRIGUEZ GONZALEZ, Appellant, and moves for an extension of time in which to file the Appellant’s brief, until and including Monday, August 31, 2015, and would further show as follows: A. The deadline for filing the brief in this cause was July 31, 2015; B. A request is hereby made for an extension of time to file the Appellant’s Brief, until and including August 31, 2015; C. The undersigned attorney, Bob Wicoff, has been unusually busy with other matters which have kept him from completing the brief by the current deadline, including, but not limited to, the following: CASEY HOLMES DYER VS. THE STATE OF TEXAS; NO. 14-15-00075- CR; Appellant’s Brief filed July 16, 2015. RUSSELL GREEN VS. THE STATE OF TEXAS; NO. 14-15-00210-CR; Appellant’s Brief filed August 3, 2015. Additionally, the undersigned serves on the Texas Forensic Science Commission Hair Microscopy Panel, as part of a team reviewing hundreds of cases involving possible errors in expert testimony. This assignment is consuming a large amount of the undersigned’s time. Counsel is also scheduled to speak at two CLEs in the next month. D. No previous extensions have been requested. Respectfully submitted, ALEXANDER BUNIN Chief Public Defender Harris County Texas /s/ Bob Wicoff__________ BOB WICOFF 1201 Franklin, Thirteenth Floor Houston Texas 77002 (713) 274-6781 TBA No. 21422700 Bob.wicoff@pdo.hctx.net CERTIFICATE OF SERVICE A true copy of this motion has been served electronically on the Harris County District Attorney’s Office Appellate Division on August 11, 2015. /s/_Bob Wicoff_________ BOB WICOFF