Ever Rodriguez Gonzalez v. State

ACCEPTED 01-15-00395-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 10/5/2015 12:00:00 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 10/3/2015 12:13:42 PM X CHRISTOPHER A. PRINE VS. X FOR THE STATE OF TEXAS Clerk X X THE STATE OF TEXAS X 1ST JUDICIAL DISTRICT MOTION FOR FINAL 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, October 12, 2015, and would further show as follows: A. The deadline for filing the brief in this cause was September 28, 2015; B. A request is hereby made for an extension of time to file the Appellant’s Brief, until and including Monday, October 12, 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: KENNETH BROWN VS. THE STATE OF TEXAS; NO. 01-15-00357-CR; Appellant’s Brief due October 5, 2015. Additionally, the undersigned serves on two panels of the Texas Forensic Science Commission, the Hair Microscopy Panel and the DNA Mixture Interpretation Panel, both of which consume a large amount of the undersigned’s time and typically require weekly out-of-town travel. Counsel has also spoken at two CLEs in the past month, including a symposium in Boston on September 25, 2015 at Northeastern law School. D. Two previous extensions have been granted. No further extensions will be needed. WHEREFORE, the Appellant requests that the deadline for filing his brief in this case be extended until and including October 12, 2015. 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 October 3, 2015. /s/_Bob Wicoff_________ BOB WICOFF