Jones, Andrew Olevia

PD-0587-1 COURT OF CRIMINAL APPEAL FILED IN AUSTIN, TEXA COURT OF CRIMINAL APPEALS Transmitted 11/13/2015 2:33:53 Pf Accepted 11/13/2015 2:35:58 Pf November 13, 2015 ABEL ACOST No. PD-0587-15 CLER ABELACOSTA, CLERK In the v_.uart of Criminal Appeals of Texas At Austin No. 01-14-00501-CR In the Court of Appeals for the First District of Texas At Houston ANDREW OLEVIA JONES Appellant v. THE STATE OF TEXAS Appellee STATE'S MOTION FOR EXTENSION OF TIME FOR FILING OF BRIEF ON APPELLANT'S PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE COURT OF CRIMINAL APPEALS OF TEXAS: COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.5(b)(1) and 70.3 of the Texas Rules of Appellate Procedure, and files this motion for extension of time in which to file the State's brief on the appellant's petition for discretionary review in this cause, and, in support thereof, presents the following: 1. In the 338th District Court of Harris County, Texas, in cause number 1390646, on May 14, 2014, Appellant was convicted in The State of Texas v. Andrew Olevia Jones. 2. For the offense of assault of a family member, Appellant's punishment was assessed at 15 years in prison. 3. A written notice of appeal was filed on June 4, 2014. 4. The First Court of Appeal dismissed Appellant's appeal on April 14, 2015. 5. The appellant's petition for discretionary review was granted by this Court on August 26, 2015. 6. The appellant's brief in support of the petition for discretionary review was filed with this Court on October 9, 2015. 7. An extension of time in which to file the State's brief on the appellant's petition for discretionary review is requested until November 13, 2015. 8. No previous extensions have been requested by the State. 9. The facts relied upon to explain the need for this extension are: The undersigned attorney is the Chief of the Appellate Division of the Harris County District Attorney's Office, and, in addition to the numerous duties accorded to his position, he is assigned to the appeal in the appellant's case. WHEREFORE, the State prays that this Court will grant an extension of time until November 13, 2015 in which to file the State's brief on the appellant's petition for discretionary review in this case. Respectfully submitted, Isi /fa* &my ALAN CURRY Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 TBC No. 05263700 curry_alan@dao.hctx.net CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument has been mailed to the appellant's attorneys at the following addresses on November 13, 2015: Melissa Martin Attorney at Law 1201 Franklin, 13th Floor Houston, Texas 77002 Isi /tOut @cmy ALAN CURRY Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 TBC No. 05263700 curry_alan@dao.hctx.net Date: November 13, 2015