Damian Scott v. State

ACCEPTED 01-15-00053-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 3/3/2015 4:00:41 PM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS OF TEXAS FIRST JUDICIAL DISTRICT FILED IN DAMIEN SCOTT § 1st COURT OF APPEALS HOUSTON, TEXAS § 3/3/2015 4:00:41 PM vs. § Case No. 01-15-00053 &54-CR CHRISTOPHER A. PRINE § Clerk THE STATE OF TEXAS § MOTION TO EXTEND TIME TO FILE BRIEF TO THE HONORABLE JUSTICES OF THIS COURT: Appellant Damien Scott, through counsel, moves the Court to extend time to file his brief, due March 3, 2015, for the following reasons: 1. Counsel, Assistant Public Defender, Melissa Martin has been working on many cases including, but not limited to Calles v. State, 14-14-00696-CR; Hayes v. State, 01-14- 00623-CR; Ramos v. State, 01-14-00831-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. Scott asks the Court to extend the time to file his brief for 30 days, or up to and including April 2, 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 March 3, 2015. /s/Melissa Martin _____________________________________ Melissa Martin