ACCEPTED
01-13-00778-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/23/2015 8:56:46 AM
CHRISTOPHER PRINE
CLERK
No. 01-13-00778-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
For the 3/23/2015 8:56:46 AM
First District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston
♦
No 1380317
In the 351st District Court
Of Harris County, Texas
♦
DANIEL GONZALEZ RODRIGUEZ
Appellant
v.
THE STATE OF TEXAS
Appellee
♦
State’s First Motion for Extension
Of Time to File Brief
♦
To the Honorable Court of Appeals:
The State of Texas, pursuant to TEX. R. APP. P. 2 & 10.5, moves for an
extension of time in which to file its appellate brief. The following facts are
relevant:
1. The appellant was charged by indictment with kidnapping. (CR 21).
The indictment alleged two prior felony convictions, with one offense
committed after the other conviction became final. (CR 21). A jury
found him guilty as charged. (CR 50, 51). The appellant pled true to
both enhancement paragraphs and the trial court assessed
punishment at thirty years’ confinement. (CR 50). The appellant filed
a timely notice of appeal and the trial court certified his right of
appeal. (CR 55, 58).
2. The State’s brief is due on March 23, 2015. The State requests a 30-
day extension of time in which to file its brief.
3. This is the State’s first request for extension.
4. The following facts are relied upon to show good cause for an
extension of time to allow the State to file its brief:
a. This case was assigned to the undersigned attorney on March
4, 2015. Since that time, he has worked on the following
mattters:
1. Craig Gilder
No. 14-14-00523-CR
Brief filed March 6, 2015
2. Julio Alvarado
Nos. 01-13-00894-CR & 01-13-00895-CR
Brief filed March 19, 2015
3. Hugo Pachas-Luna
Nos. 01-14-00516-CR et seq.
Brief due March 23, 2015 (third motion for extension filed)
b. The undersigned attorney was out of the office for a medical
procedure on March 20, 2015.
WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted,
/s/ C.A. Morgan
CLINTON A. MORGAN
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
morgan_clinton@dao.hctx.net
TBC No. 24071454
CERTIFICATE OF SERVICE
I certify that I have requested that efile.txcourts.gov electronically serve
a copy of this motion to:
Kurt B. Wentz
kbsawentz@yahoo.com
/s/ C.A. Morgan
CLINTON A. MORGAN
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
morgan_clinton@dao.hctx.net
TBC No. 24071454
Date: March 23, 2015