ACCEPTED
01-15-00593-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
9/22/2015 10:02:01 AM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS FOR THE
FIRST DISTRICT OF TEXAS
NO. 01-15-00593-CR FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
9/22/2015 10:02:01 AM
TROY XAVIER EVANS CHRISTOPHER A. PRINE
Appellant, Clerk
On Appeal From the 174th
District Court of Harris County
V. Trial Cause No. 1423548
THE STATE OF TEXAS
Appellee
FIRST 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. Troy Xavier
Evans Cause Number 1423548 in the 174th District Court of Harris County. Evans
was found guilty of burglary of a habitation and sentenced to twenty-five (25) years
confinement in the Texas Department of Criminal Justice – Institutional Division.
Notice of Appeal was timely filed. The brief is due on September 23, 2015. No prior
extensions have been requested.
II.
Counsel will be unable to file the brief in this cause as has been completing the
following tasks:
1. Preparing and filing a brief in Erick Hernandez v. State of Texas, 14-15-
00209-CR which was filed on August 19, 2015.
2. Preparing and filing a brief in Willie Clarke v. State of Texas, 01-15-00547-
CR, 01-15-00548-CR, 01-15-00549-CR which was filed on September 4,
2015.
3. Counsel had been doing extensive investigation into a possible Motion
for New Trial in State of Texas v. Christopher Cavazos, Cause Numbers
1402280 and 1443325 in the 184th District Court of Harris County. The
deadline for filing a Motion for New Trial was September 9, 2015.
4. Preparing and filing a Petition for Discretionary Review in Lajuan Cecile
Bailey v. State of Texas, Cause No. PD-1087-15 which was filed on
September 21, 2015.
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 September 2015 a copy of the foregoing instrument
has been electronically served upon the State of Texas.
/s/ Angela Cameron
ANGELA CAMERON