ACCEPTED
01-15-00177-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
9/28/2015 2:02:44 PM
CHRISTOPHER PRINE
CLERK
Number 01-15-00177-CR
in the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
for the 9/28/2015 2:02:44 PM
First District of Texas CHRISTOPHER A. PRINE
at Houston, Texas Clerk
Number 1369135
In the 208th District Court
of Harris County, Texas
Nathaniel Ambrose Petty
Appellant
V.
The State of Texas
Appellee
Motion to Extend Time to File Original Brief
Appointed Counsel :
Ellis McCullough
TBN 13501000
4008 Louetta Road #365
Spring, Texas 77388
(281)433-9240
Comes now Ellis McCullough, Counsel for Appellant and moves to extend time to
file Appellant’s original brief and would show:
1. Counsel was informed by an attorney whose name is forgotten that he was hired
to prepare Appellant’s original brief. Either Counsel’s memory is defective or said
attorney did not follow through on his decoration.
2. Counsel has three trials set in the next four weeks. Counsel requests an
extension of time to prepare Appellant’s brief of forty five days.
Wherefore, counsel requests an extension of time to prepare Appellant’s brief of
forty five days.
Respectfully Submitted,
/s/Ellis McCullough
Ellis McCullough
TBN 13501000
4008 Louetta Road, #365
Spring, Texas 77388
(281)433-9240
2
Certificate of Service
I, the undersigned attorney, do hereby certify that a true copy of the attached
instrument has been delivered to all parties as required by law on September 28, 2015.
/s/Ellis McCullough
Ellis McCullough
3