ACCEPTED
14-15-00345-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
10/8/2015 3:29:50 PM
CHRISTOPHER PRINE
CLERK
CASE NO. 14-15-00345-CR
IN THE 14TH COURT OF APPEALS FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
OF THE STATE OF TEXAS 10/8/2015 3:29:50 PM
CHRISTOPHER A. PRINE
Clerk
THE STATE OF TEXAS, APPELLEE
v.
NAYAJAH NIYA DAVIS, APPELLANT
Appealed from the 262nd Judicial District Court
Harris County, Texas
Trial Cause No. 1412475
APPELLANT’S MOTION FOR EXTENSION OF
TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
Comes now, Appellant, Nayajah Niya Davis, and files this, her motion for extension
of time to file Appellant’s Brief on the Merits. The Appellant has neither requested nor been
granted a previous extension of time to file Appellant’s brief.
The facts reasonably relied upon to explain the need for an extension of time are as
follows:
The issue(s) before the Court is/are believed, by the Appellant, to be of tremendous
importance. The issue involves a great deal of research on a number of issues involving
Brady/exculpatory materials, intelligent and knowing waivers of certain constitutional
rights, and issues related to subpoena(s) and protective orders.
Additionally, the Appellant’s Attorney is currently finalizing appellate briefs in
COA No. 10-15-00155-CR; Ester Porras Natividad v. The State of Texas and COA No. 10-15-
00007-CR; Yvonne Carol Lindsey v. The State of Texas.
Counsel for Appellant respectfully requests the Honorable Court to grant a ninety
(90) day extension, or in the alternative a sixty (60) day extension in order that the
Appellant can procure the money needed to obtain the Court Reporter’s Record and allow
for her attorney to properly review the record and prepare an appropriate brief addressing
the issues anticipated to be raised.
Respectfully submitted,
/s/ J. Paxton Adams
_______________________________
J. Paxton Adams
Attorney at Law
SBN: 24042459
1113 Twelfth Street
Huntsville, Texas 77340
Tel. (936) 291-9900
Fax (936) 291-9903
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
I do hereby certify that a copy of the foregoing Appellant’s Motion for Extension of
Time to File Appellant’s Brief was forwarded to the following, on this the 8th day of
October, 2015.
/s/ J. Paxton Adams
___________________________
J. Paxton Adams