ACCEPTED
01-14-00361-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/14/2015 9:49:54 AM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS OF TEXAS
FIRST JUDICIAL DISTRICT
FILED IN
BLAKE ANTHONY MONAKINO § 1st COURT OF APPEALS
HOUSTON, TEXAS
§ 12/14/2015 9:49:54 AM
VS. § CASE NO. 01-14-00361-CR
CHRISTOPHER A. PRINE
§ Clerk
THE STATE OF TEXAS §
MOTION TO EXTEND TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THIS COURT:
Appellant asks the Court to extend time to file his brief from December 9, 2015,
for 30 days for the following reasons:
1. The Court granted appellant’s motion to abate for a complete record on April
16, 2015. On October 9, 2015 the appeal was reinstated with a due date of November
9, 2015.
2. When the case was reinstated, counsel was working on Carter v. State, 01-14-
01006-CR, which was filed on November 6, 2015. In addition, counsel is working on
meeting deadlines on five cases due between this date and December 1, 2015.
4. Counsel has submitted two briefs since the previous extension request and has
four imminent deadlines as of this writing: Cameron v. State, 14-15-00447-CR, due
December 14, 2015, Bonds v. State, 14-15-00688-CR, due December 15, 2015; Humphrey
v. State, 14-150026-CR (felony murder, with hearing on a motion for new trial), due
December 18, 2015; and Sanchez v. State, 01-15-00609-CR, due December 23, 2015; as
well as the instant case and despite due diligence has been unable to fully review the
new information obtained during the abatement.
5. As this Court is probably aware, this office has been short of three appellate
lawyers for several months. Two new lawyers have now begun work, one as of
November 30 and the other as of December 7, 2015; they are helping with the divisions
backlog but it will take a month or so before everyone has caught up. This writer will
be using the upcoming holidays to expedite this process and asks the Court for its
patience.
In view of the forgoing, we request an extension of 30 days from December 9,
2015 to January 9, 2016.
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 14, 2015.
/s/ Melissa Martin
__________________________
Melissa Martin
Blake Anthony Monakino v. State
Combined Opinion