ACCEPTED
01-15-00782-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/12/2015 10:28:53 AM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS FOR THE
FIRST DISTRICT OF TEXAS
NO. 01-15-00781-CR FILED IN
NO. 01-15-00782-CR 1st COURT OF APPEALS
HOUSTON, TEXAS
11/12/2015 10:28:53 AM
CHRISTOPHER CAVAZOS CHRISTOPHER A. PRINE
Appellant, Clerk
On Appeal From the 184th
District Court of Harris County
V. Trial Cause Nos. 1402280 &
1443325
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 convictions for intoxication manslaughter
and intoxication assault in The State of Texas v. Christopher Cavazos Cause Number
1402280 and 1443325 in the 184th District Court of Harris County. Cavazos pled to
both cases without an agreed recommendation and the cases were set for a Pre-
Sentence Investigation hearing. After a hearing, the trial court sentenced Appellant to
sixteen (16) years for intoxication manslaughter and nine (9) years for intoxication
assault. Notice of Appeal was timely filed. The brief is due on November 12, 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 Lawson Echeta v. State of Texas, Cause No.
01-15-00557-CR which was filed on October 19, 2015
2. Investigation and filing of a Motion for New Trial in State of Texas v. Huey
Jones, Cause Number 1463572 in the 177th District Court of Harris
County. Counsel is continuing to investigate and prepare for a hearing
which is set on November 23, 2015.
3. Investigation and filing of a Motion for New Trial in State of Texas v.
Joshua Barnett, Cause Number 1451490 in the 230th District Court of
Harris County. The Motion was filed on November 11, 2015. Counsel is
continuing to investigate and prepare for a hearing which is set on
November 25, 2015.
4. Investigation into a possible Motion for New Trial in State of Texas v.
Daniel Sanders, Cause Number 1438488 in the 184th District Court of
Harris County. The deadline for filing a Motion for New Trial is
December 3, 2015.
5. The Appellate Division of the Harris County Public Defender’s Office
has been short staffed requiring each attorney to be assigned more cases
than normal. Two individuals have been hired but will not begin working
at the PDO until November 30, 2015 and December 7, 2015.
6. Counsel also has the briefs currently due in the following cases:
a. Troy Evans v. State of Texas, 01-15-00209-CR which is due on
November 23, 2015 after 2 prior 30 day extensions have been
granted.
b. Elijah Reed v. State of Texas, 01-15-00481-CR which is due on
November 20, 2015 after one prior 30 day extension has been
granted.
c. Jamon Walker v. State of Texas, 14-15-00685-CR which is due on
November 23, 2015 after one prior 30 day extension has been
granted.
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 12th day of November 2015 a copy of the foregoing instrument
has been electronically served upon the State of Texas.
/s/ Angela Cameron
ANGELA CAMERON