ACCEPTED
01-14-00861-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/8/2015 5:56:03 AM
CHRISTOPHER PRINE
CLERK
No. 01-14-00861-CR
In the
Court of Appeals FILED IN
For the 1st COURT OF APPEALS
HOUSTON, TEXAS
First District of Texas 4/8/2015 5:56:03 AM
At Houston CHRISTOPHER A. PRINE
Clerk
No. 1388920
In the 184th District Court of
Harris County, Texas
SEGISMUNDO GONZALEZ
Appellant
v.
THE STATE OF TEXAS
Appellee
STATE’S MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE APPELLATE BRIEF
TO THE HONORABLE COURT OF APPEALS OF TEXAS:
COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.5(b)(1)
and 38.6(d) of the Texas Rules of Appellate Procedure, and files this motion for
extension of time in which to file the State’s brief in these cases, and, in support
thereof, presents the following:
1. In the 184th district court of Harris County, Texas, cause 1388920, the State of
Texas v. Segismundo Gonzalez, appellant, was convicted of theft.
2. He was assessed punishment of confinement for 17 years in the Institutional
Division of the Texas Department of Criminal Justice.
3. The State’s brief was due on April 3, 2015.
4. An extension of time in which to file the State’s brief is requested until
March 18, 2015.
5. No previous extensions have been requested by the State.
6. The facts relied upon to explain the need for this extension are:
Since appellant filed his brief, I have filed briefs in cause numbers 14-14-
00204-CR and 14-14-00777-CR. In addition to the present case, I have 3 briefs
assigned to me, am recreating exhibits for an abatement hearing in cause
number 14-13-00767-CR, and am preparing for trial on May 4th, 2015 on the
State of Texas v. Sidney Darrell in cause number 1421932. Additionally, I assist
trial court prosecutors with legal questions on a daily basis. This motion is not
sought for delay, but so that justice may be done.
WHEREFORE, the State prays that this Court will grant an extension of time
until March 9, 2015 in which to file the State’s brief in this case.
Respectfully submitted,
/s/ Abbie Miles
Abbie Miles
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 24072240
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been mailed to the
appellant’s attorney at the following address on April 8, 2015:
Leah M. Borg
874 Yorkchester No. 123
Houston, TX 77079
Borg579@att.net
/s/ Abbie Miles
Abbie Miles
Assistant District Attorney
Harris County, Texas
Date: April 8, 2015