ACCEPTED
01-14-01032-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/17/2015 11:19:38 AM
CHRISTOPHER PRINE
CLERK
01-14-001032-CR & 01-14-01033-CR
In the
Court of Appeals FILED IN
For the 1st COURT OF APPEALS
HOUSTON, TEXAS
First District of Texas 8/17/2015 11:19:38 AM
At Houston CHRISTOPHER A. PRINE
Clerk
No. 1387546 & 1387547
In the 351st District Court of
Harris County, Texas
WILLIAM MONTERIAL JONES
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 these cases, and, in support
thereof, presents the following:
1. In the 351st district court of Harris County, Texas, cause numbers 1387546
& 1387547, the State of Texas v. William Monterial Jones, appellant, was
convicted of aggravated robbery with a deadly weapon and felon in
possession of a weapon.
2. He was assessed punishment of confinement for 40 years in the Institutional
Division of the Texas Department of Criminal Justice.
3. The State’s brief is due on July 29, 2015.
4. An extension of time in which to file the State’s brief is requested until
August 28, 2015.
5. One previous extension has been requested by the State.
6. The facts relied upon to explain the need for this extension are:
Since my last motion for extension, I have filed a brief in cause number
01-14-00831-CR. I was in Austin from July 8 through July 9th to attend the
disciplinary committee meeting regarding In the Matter of Sondra Humphrey, Cause
No. CSR-15-06160-021. Additionally, I answer trial court questions from other
prosecutors on a daily basis. Also, I was on vacation from July 23rd through July
28th. This motion is not sought for delay, but so that justice may be done.
WHEREFORE, the State prays that this Court will grant an extension of time
until August 28, 2015 in which to file the State’s brief in this case.
Respectfully submitted,
/s/ Abbie Miles
Abbie Miles
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 24072240
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been mailed to the
appellant’s attorney at the following address on July 29, 2015:
Ann Lee Moseley
2002 Timberloch Place, #200
The Woodlands, TX 77380
/s/ Abbie Miles
Abbie Miles
Assistant District Attorney
Harris County, Texas
Date: July 29, 2015