ACCEPTED
14-15-00497-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
10/2/2015 2:56:21 PM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS FOR THE
FOURTEENTH DISTRICT COURT OF APPEALS
HOUSTON, TEXAS FILED IN
NO. 14-15-00496-CR, 14-15-00497-CR 14thHOUSTON,
COURT OF APPEALS
TEXAS
TREY FOSTER 10/2/2015 2:56:21 PM
APPELLANT On Appeal from Cause Number 1374929
CHRISTOPHER A. PRINE
From the 228 District Court Clerk
th
Harris County, Texas
V.
THE STATE OF TEXAS
APPELLEE
APPELLANT’S MOTION FOR EXTENSION
TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF
APPEALS:
COMES NOW, Trey Foster, and files this Motion to Extend Time to File Brief, and in
support thereof, would respectfully show the Court the following:
I.
The current deadline for filing Appellant’s Brief is September 21, 2015. There has been
one previous motion for extension of time to file Appellant’s Brief.
II.
Counsel has been engaged in work in the Harris County Public Defender’s Office on
many cases, including the following:
Lenin Lopez, 01-13-01079-CR, reversed and set for rehearing in cause #1403196
Felix Irizarry, 14-14-00827-CR
Darryle Robertson, 14-15-00132-CR
Ruben Totten, PD-0483-15
Domingo Medina, 01-15-00574-CR
Stephen Hopper, 14-15-00371-CR
Pete Rodriguez, 14-15-00339-CR
Craig Beal, 01-12-00896-CR
Kori Henegar, 14-15-00529-CR
Counsel has been researching and writing for several trial cases assigned to the
Public Defender’s Office Trial Division.
III.
Appellant’s attorney requests this extension which is necessary so that the brief can be
thoroughly written and timely filed. This motion is not made for the purpose of delay.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable
Court grants this extension to November 2, 2015.
Respectfully Submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County, Texas
/s/ Sarah V. Wood
SARAH V. WOOD
Assistant Public Defender
Harris County, Texas
Texas Bar Number 24048898
1201 Franklin, 13th Floor
Houston, Texas 77002
Phone: (713) 368-0016
Fax: (713) 368-9278
Sarah.Wood@pdo.hctx.net
CERTIFICATE OF SERVICE
By my signature below, I hereby certify that a true and correct copy of the above and
foregoing has been served upon the Harris County District Attorney's Office – Alan
Curry, via the electronic filing service.
/s/ Sarah V. Wood
Sarah V. Wood