ACCEPTED
14-15-00209-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
6/22/2015 12:45:57 PM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS FOR THE
FOURTEENTH DISTRICT OF TEXAS
NO. 14-15-00209-CR FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
ERICK EDUARDO HERNANDEZ 6/22/2015 12:45:57 PM
Appellant, CHRISTOPHER A. PRINE
On Appeal 184th
From theClerk
District Court of
Harris County, Texas
V. Trial Cause No. 1392161
THE STATE OF TEXAS
Appellee
SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
ANGELA CAMERON, attorney of record for Appellant in the above cause,
would respectfully request the Court to grant her motion to extend time for file brief.
In support of said motion, counsel would show unto the Court the following:
I.
This appeal lies from Appellant's conviction in The State of Texas v. Erick
Hernandez Cause Number 1392161 in the 184th District Court of Harris County.
Hernandez was found guilty of murder and sentenced to life imprisonment in the
Texas Department of Corrections. Notice of Appeal was timely filed. The brief is
due on June 22, 2015. One prior extension has been granted.
II.
Counsel will not be able to file the brief for the following reasons:
1. Counsel was out of the office the week of May 25th through June
1, 2015 due to Memorial Day, Flooding in Downtown and
attending the Conference on Criminal Appeals CLE in Austin.
2. Counsel has been helping in the trial preparation in State of Texas v.
Gaylin Lavan, Cause Number 1440861 in the 183rd District Court of
Harris County. The case was set for trial on June 8, 2015.
3. Counsel has been helping in the trial preparation in State of Texas v. Rusty
Terry, Cause Number 1451197 in the 183rd District Court of Harris
County. The case was set for trial on June 8, 2015.
4. Counsel has been helping in the trial preparation in State of Texas v. Tonia
Haskett, Cause Number 1439465 in the 180th District Court of Harris
County. The case was set for trial on June 15, 2015.
5. Counsel has been helping in the trial preparation in State of Texas v. Derek
Boone, Cause Number 1416801 in the 228th District Court of Harris
County. The case was set for trial on June 22, 2015.
6. Counsel was preparing for oral argument in State of Texas v. Issac Smith,
Cause Number 14-14-00139-CR which was held on June 17, 2015.
7. Counsel has been investigating a possible Motion for New Trial in State
of Texas v. Willie Clarke, Cause Numbers 1453864, 1457279 and 1465671
in the 178th District Court of Harris County. The deadline for filing a
Motion for New Trial is June 27, 2014.
VI.
An extension of time is necessary so that the brief can be timely filed. This
motion is not made for the purpose of delay.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this
Honorable Court will grant this requested extension of time to file the Appellant's
Brief in the above cause and extend the time for filing the brief for at least thirty (30)
days.
Respectfully submitted,
Alexander Bunin
Chief Public Defender
/s/ Angela Cameron
Angela Cameron
State Bar No. 00788672
Harris County Public Defender’s Office
1201 Franklin 13th Floor
Houston, Texas 77002
Tel: 713-368-0016
angela.cameron@pdo.hctx.net
CERTIFICATE OF SERVICE
I certify that on the 22nd day of June 2015 a copy of the foregoing instrument has
been electronically served upon the State of Texas.
/s/ Angela Cameron
ANGELA CAMERON