Andreas Marcopoulos v. State

ACCEPTED 01-15-00317-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 8/21/2015 3:22:39 PM CHRISTOPHER PRINE CLERK Cause No. 01-15-00317-CR IN THE COURT OF APPEALS FILED IN 1st COURT OF APPEALS FOR THE HOUSTON, TEXAS FIRST JUDICIAL DISTRICT OF TEXAS8/21/2015 3:22:39 PM AT HOUSTON CHRISTOPHER A. PRINE Clerk ANDREAS MARCOPOULOS, Appellant v. THE STATE OF TEXAS, Appellee. Appeal from Cause No. 1440970 In the 248th District of Harris County, Texas ____________________________________________________________________ APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE JUSTICES OF THE FIRST DISTRICT COURT OF APPEALS: Appellant, ANDREAS MARCOPOULOS, by and through his Counsel of Record, CARMEN ROE and ROBERT FICKMAN, files this Motion to Extend Time to File Brief For Appellant and in support shows this Court the following: I. Appellant was charged with possession of a controlled substance in Cause No. 1440970 in the 248th District Court of Harris County Texas. Appellant entered a plea of guilty and was placed on deferred adjudication probation for three (3) years. II. The Reporter’s Record was filed on June 22, 2015 and the Clerk’s Record was filed on June 24, 2015. Appellant’s Brief is currently due on August 20, 2015, after one extension was granted. III. Appellant requests an extension of thirty (30) days until September 21, 2015 to file its brief. Counsel requests the additional time because undersigned counsel has the following briefs do in the next 30 days: State v. Mashood Uddin, State v. Jordan Nichols, State .v Christopher Redmond Reply Brief as well as writs of habeas corpus in Ex parte Michael Hill, Ex parte Bryant Williams, and Ex parte Jerrell Bell. For all these reasons, Counsel is unable to submit the Appellant’s Brief on the due date and hereby requests an extension of time. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court extend the time for filing Appellant’s Brief in this cause until September 21, 2015. RESPECTFULLY SUBMITTED, /s/ Carmen Roe _________________________________ CARMEN ROE CARMEN ROE LAW FIRM SBN: 24048773 440 Louisiana, Suite 900 Houston, Texas 77002 713.236.7755 Phone 713.236.7756 Fax carmen@carmenroe.com /s/ Robert Fickman __________________________________ ROBERT FICKMAN SBN: 06956500 1229 Heights Boulevard Houston, Texas 77008 713.655.7400 Phone 713.224.5533 Fax rfickman@gmail.com ATTORNEYS FOR APPELLANT ANDREAS MARCOPOULOS CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing was served upon the Harris County District Attorney, Appellate Division, 1201 Franklin Street, Houston, Texas 77002, on August 21, 2015. /s/ Carmen Roe _____________________________ CARMEN ROE