ACCEPTED
01-15-00560-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
9/18/2015 2:59:08 PM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS FOR THE
FIRST DISTRICT COURT OF APPEALS
HOUSTON, TEXAS FILED IN
NO. 01-15-00560-CR 1st COURT OF APPEALS
HOUSTON, TEXAS
MICHAEL ANTHONY DAVILA 9/18/2015 2:59:08 PM
APPELLANT On Appeal from Cause Number 1359876
CHRISTOPHER A. PRINE
From the 351 District Court Clerk
st
Harris County, Texas
V.
THE STATE OF TEXAS
APPELLEE
APPELLANT’S MOTION FOR EXTENSION
TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS:
COMES NOW, Michael Anthony Davila, and files this Motion to Extend Time to File
Brief, and in support thereof, would respectfully show the Court the following:
I.
The current deadline for filing Appellant’s Brief is September 16, 2015. There have not
been any previous motions for extension of time to file Appellant’s Brief.
II.
Counsel has been engaged in work in the Harris County Public Defender’s Office on
many cases, including the following:
Lenin Lopez, 01-13-01079-CR, reversed and set for rehearing in cause #1403196
Felix Irizarry, 14-14-00827-CR
Darryle Robertson, 14-15-00132-CR
Ruben Totten, PD-0483-15
Trey Foster, 14-15-00497-CR
Pete Rodriguez, 14-15-00339-CR
Craig Beal, 01-12-00896-CR
Kori Henegar, 14-15-00529-CR
Counsel has been researching and writing for several trial cases assigned to the
Public Defender’s Office Trial Division.
III.
Appellant’s attorney requests this extension which is necessary so that the brief can be
thoroughly written and timely filed. This motion is not made for the purpose of delay.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable
Court grants this extension to October 18, 2015.
Respectfully Submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County, Texas
/s/ Sarah V. Wood
SARAH V. WOOD
Assistant Public Defender
Harris County, Texas
Texas Bar Number 24048898
1201 Franklin, 13th Floor
Houston, Texas 77002
Phone: (713) 368-0016
Fax: (713) 368-9278
Sarah.Wood@pdo.hctx.net
CERTIFICATE OF SERVICE
By my signature below, I hereby certify that a true and correct copy of the above and
foregoing has been served upon the Harris County District Attorney's Office – Alan
Curry, via the electronic filing service.
/s/ Sarah V. Wood
Sarah V. Wood