ACCEPTED
01-14-00902-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
2/10/2015 6:34:07 AM
CHRISTOPHER PRINE
CLERK
No. 01-14-00902-CR
In the FILED IN
Court of Appeals 1st COURT OF APPEALS
HOUSTON, TEXAS
for the
2/10/2015 6:34:07 AM
First District of Texas
at Houston CHRISTOPHER A. PRINE
Clerk
No. 1399343
In the 230th District Court
Harris County, Texas
KENNETH ALLEN ROSS
Appellant
V.
THE STATE OF TEXAS
Appellee
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE APPELLATE BRIEF
TO THE HONORABLE COURT OF APPEALS:
APPELLANT, pursuant to TEX. R. APP. P. 10.1, 10.5(b) and 38.6(d), moves
for an extension of time within which to file its appellate brief. In support of its
motion, appellant submits the following:
1. Appellant was charged with aggravated robbery.
2. A jury convicted appellant of the charged offense and the jury sentenced
him to 40 years confinement in the Institutional Division of the Texas
Department of Criminal Justice on October 30, 2014.
3. Notice of appeal was filed on October 30, 2014.
4. Appellant’s brief was due on January 28, 2015.
5. Appellant seeks an extension to file his brief until April 6, 2015.
6. The following facts are relied upon to show good cause for the
requested extension:
a. Counsel has been acting as co-counsel on a case involving Garcia
Glen White. Mr. White was set to be executed on January 28, 2015.
b. Counsel had been preparing for a hearing on a capital case, Ex parte
Williams, Cause No. 1088181-A, set for January 14, 2015.
c. Counsel has filed subsequent writs in Ex parte Williams, Cause Nos.
1088181-B and 1088181-C.
d. Counsel has been working on Dorsey v. State, No. 01-14-00685-CR
7. Appellant’s motion is not for purposes of delay, but so that justice may
be done.
WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted,
/s/MANDY MILLER
Attorney for appellant
2910 Commercial Center Blvd., Ste. 103-201
Katy, TX 77494
SBN 24055561
PHONE (832) 900-9884
FAX (877) 904-6846
mandy@mandymillerlegal.com
2
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been delivered via
email to the following address:
Harris County District Attorney’s Office
ATTN: Alan Curry
1201 Franklin, Suite 600
Houston, Texas 77002
Curry_Alan@dao.hctx.net
/s/MANDY MILLER
Attorney for appellant
2910 Commercial Center Blvd., Ste. 103-201
Katy, TX 77494
SBN 24055561
PHONE (832) 900-9884
FAX (877) 904-6846
mandy@mandymillerlegal.com
3