ACCEPTED
01-15-00672-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/1/2015 9:12:30 AM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS OF TEXAS
FIRST JUDICIAL DISTRICT
FILED IN
ALTON JOSEPH JOLIVETTE, JR. § 1st COURT OF APPEALS
HOUSTON, TEXAS
§ CASE NOS.12/1/2015
01-15-00672-CR
9:12:30 AM
VS. § 01-15-00673-CR
CHRISTOPHER A. PRINE
§ 01-15-00674-CR
Clerk
THE STATE OF TEXAS §
MOTION TO EXTEND TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THIS COURT:
Appellant Alton Joseph Jolivette, through counsel, moves the Court to extend
time to file his brief, due November 30, 2015, for the following reasons:
1. Counsel, Assistant Public Defender, Melissa Martin has been working on many
cases including, but not limited to Humphrey v. State , 14-15-00226-CR; Hill v State, 01-14-
00945-CR; Bonds v. State, 01-15-00688-CR; Davison v. State, 14-14-00511-CR; and Cameron
v. State, 14-15-00447-CR, as well as the instant case and has been unable to complete the
brief despite due diligence.
2. This is the first request for an extension in this case.
In view of the foregoing, Mr. Jolivette asks the Court to extend the time to file
his brief for 30 days, or up to and including December 30, 2015. This request is made
in the interest of justice and effective assistance of counsel and not for purposes of
delay.
Respectfully submitted,
ALEXANDER BUNIN
Chief, Harris County Public Defender’s Office
/s/ Melissa Martin
_________________________________
MELISSA MARTIN
Assistant Public Defender
TX. Bar No. 24002532
1201 Franklin St., 13th Fl.
Houston, TX 77002
email: melissa.martin@pdo.hctx.net
713/274-6709 Fax 713/437-4319
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing motion was electronically served on the
Harris County District Attorney’s office on December 1, 2015.
/s/ Melissa Martin
__________________________
Melissa Martin