ACCEPTED
01-15-00184-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
10/20/2015 5:49:51 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00184-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
For the 10/20/2015 5:49:51 PM
First District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston
No. 1370633
In the 180th District Court
Of Harris County, Texas
JOVANTE CHARLES BANKS
Appellant
V.
THE STATE OF TEXAS
Appellee
STATE’S MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE APPELLATE BRIEF
TO THE HONORABLE COURT OF APPEALS:
THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 10.1, 10.5(b) and
38.6(d), moves for an extension of time within which to file its appellate brief. In
support of its motion, the State submits the following:
1. Appellant was convicted for the offense of aggravated sexual assault
of a child and sentenced to 14-years confinement.
2. Appellant filed written notice of appeal on February 13, 2015.
3. Appellant filed his brief on September 3, 2015.
4. The State’s reply brief is due on October 5, 2015.
5. The State seeks an extension until November 20, 2015, to file its
brief.
6. This is the State’s first request for an extension in this case.
7. The following facts are relied upon to show good cause for the
requested extension:
My completion of this brief has been delayed by my
work on two other appellate briefs this past month, as
well as by my recent preparation for and presentation of
an oral argument. I also have four other briefs due in the
coming month.
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WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted,
/s/ Dan McCrory
DAN MCCRORY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1901
(713) 755-5826
TBC No. 13489950
mccrory_daniel@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that I requested that a copy of this document be served on
appellant’s lawyer via TexFile at the following email address:
Joshua S. Hill
Attorney at Law
josh@notguiltytx.com
/s/ Dan McCrory
DAN MCCRORY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1901
(713) 755-5826
TBC No. 13489950
Date: October 20, 2015
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