ACCEPTED
01-14-00232-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/27/2015 4:15:02 PM
CHRISTOPHER PRINE
CLERK
NO. 01-14-00232-CR
IN THE COURT OF APPEALS
FILED IN
FOR THE FIRST JUDICIAL DISTRICT 1st COURT OF APPEALS
HOUSTON, TEXAS HOUSTON, TEXAS
_________________________________________________________
3/27/2015 4:15:02 PM
CHRISTOPHER A. PRINE
ARTURO CHAVEZ Clerk
Appellant
V.
STATE OF TEXAS
Appellee
__________________________________________________________
On Appeal from the 338th Judicial District Court of Harris
County, Texas - Trial Court No. 1338052
Honorable Brock Thomas
__________________________________________________________
MOTION FOR LEAVE AND EXTENSION OF TIME
TO FILE REPLY BRIEF
___________________________________________________________
TO THE HONORABLE JUDGES OF SAID COURT:
Arturo Chavez, Appellant, respectfully requests leave of court and an extension of time to
file a reply brief. Appellant’s reply brief is filed at the same time as this motion. Appellant filed
his brief on December 11, 2014. The state filed its brief in response on February 2,
2015. According to Texas Rule of Appellant Procedure 38.6(c), Appellant’s reply brief was due
by February 22, 2015.
Replying to the state’s brief took considerably more time than anticipated. Counsel
believes that the reply brief will assist the Court in narrowing and addressing the issues presented
in this appeal. For these reasons, Appellant seeks leave to file his reply brief out of time.
Respectfully submitted,
DeGUERIN, DICKSON, HENNESSY & WARD
/s/Matt Hennessy
Matt Hennessy
State Bar No. 00787677
matt@deguerin.com
1018 Preston, 7th Floor
Houston, Texas 77002
(713 223-5959 Telephone
(713) 223-9231 Facsimile
Attorney for Appellant
CERTIFICATE OF SERVICE
This will certify that a true and correct copy of the foregoing Motion for Leave and for
Extension of Time to File Reply Brief has been delivered to Alan Curry, Assistant District
Attorney, Appellate Division, 1201 Franklin, Suite 600, Houston, Texas 77002, via electronic
filing, on March 27, 2015.
/s/Matt Hennessy
Matt Hennessy
Arturo Chavez, Jr. v. State
Combined Opinion