ACCEPTED
14-15-00581-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
10/9/2015 1:49:55 PM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS
FOR THE FOURTEENTH SUPREME JUDICIAL DISTRICT
FILED IN
AT HOUSTON, TEXAS 14th COURT OF APPEALS
HOUSTON, TEXAS
10/9/2015 1:49:55 PM
LUIS EDUARDO LARA § CHRISTOPHER A. PRINE
§ Clerk
Appellant §
§
vs. § CASE NO. 14-15-00581-CR
§
§ TRIAL COURT NO. 14CR2148
THE STATE OF TEXAS §
§
Appellee §
APPELLANT’S FIRST MOTION FOR EXTENSION
OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUDGES OF THE FOURTEENTH COURT OF
APPEALS:
COMES NOW LUIS EDUARDO LARA, Appellant in the above-styled and
numbered cause, by his Counsel of Record, Greg Russell, and pursuant to
TEX.R.APP.P. 34.6(d), files this Motion For Extension of Time to File Appellant’s
and in support thereof would show this Honorable Court the following:
I.
Appellant was found guilty by a jury Sexual Assault of Child, Indecency
with a Child by Contact and Continuos Sexual Abuse Child and punishment was
assessed at 15 years, 8 Years and 28 years, respectively, Texas Department of
Criminal Justice.
II.
Appellant’s Brief was due on or before October 5, 2015.
III.
Appellant’s counsel, apparently, incorrectly imputed the due date of
Appellant’s Brief for November 5, 2015, instead of the correct due date of October
5, 2015. This was an oversight/mistake on the part of appellant’s counsel.
IV.
Additionally, appellant’s counsel has been preparing for a trial that will
begin on October 13, 2015 in Fort Bend County, that involves an automatic life
sentence upon a conviction. The case is styled The State of Texas vs. Jeremy
Lange, 14DCR65359, 14DCR65360, 14DCR65361 and 14DCR66459, in the
400th District Court. Appellant’s counsel has been preparing for this trial for most
of August and September 2015.
V.
Due to appellant’s counsel being in trial beginning October 13, 2015 in Fort
Bend that will in all liklihood last two weeks, appellant respectfully requests a 45
day extension to file Appellant’s Brief.
Appellant prays that this extension be granted and that Appellant’s Brief be
ordered due to this Court within 45 days.
Respectfully submitted,
/s/ Greg Russell
Greg Russell
Attorney for Appellant
711 59th Street
Galveston, Texas 77551
(409) 497-4743
(409) 497-4721 Fax
SBN: 174115
CERTIFICATE OF SERVICE
Pursuant to TEX.R.APP.P. 9.5(d), this motion was served on Mr. Jack Roady,
Galveston County District Attorney, 600 59th Street, 1st Floor, Galveston, Texas,
77551, by efile/email service, on October 9, 2015.
/s/ Greg Russell
Greg Russell
CERTIFICATE OF COMPLIANCE
I do hereby that this motion is in compliance with Rule 9.4(i) of the Texas
Rules of Appellate Procedure because it is computer generated and its relevant
portions contain 427 words.
/s/ Greg Russell
Greg Russell