Harold James Harris v. State

ACCEPTED 04-14-00888-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 5/4/2015 10:41:59 AM KEITH HOTTLE No. 04-14-00888-CR CLERK IN THE COURT OF APPEALS FOR THE FOURTH JUDICIAL DISTRICT OF TEXAS, AT SAN ANTONIOFILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS Harold James Harris, 5/4/2015 10:41:59 AM Appellant KEITH E. HOTTLE v. Clerk The State of Texas, Appellee On Appeal from the County Court at Law No. 1 of Bexar County in Cause No. 384759, the Hon. John Fleming, Judge Presiding Motion for Extension of Time To File Appellant’s Brief on Appeal TO THE HONORABLE FOURTH COURT OF APPEALS: COMES NOW, Harold James Harris, Appellant in the above styled and numbered cause, by and through David A. Schulman, his undersigned attorney of record, and respectfully enters this “Motion for Extension of Time to File Appellant’s Brief on Appeal,” and in support of such Motion would show the Court: I Appellant was convicted of driving while intoxicated. Punishment was assessed at 180 days in jail and a $1,000 fine. The trial court imposed sentence on December 5, 2014. Notice of Appeal was timely filed with the clerk of the trial court the same day. II The deadline for filing Appellant’s Brief with the Court is May 6, 2015. Appellant’s request for an extension is based upon the inability of the undersigned attorney to finish research on the issues raised by the trial of the case. Said attorney would further show that he will require an additional forty-five (45) days in which to complete the research and prepare Appellant’s Brief on Appeal. This is Appellant’s first request for an extension of time in which to file his brief. Prayer WHEREFORE PREMISES CONSIDERED, Appellant prays this Honorable Court to grant his “Motion for Extension of Time to File Brief on Appeal,” and Order that the deadline for filing such be extended an additional forty-five (45) days, until June 22, or until such time as set by this Court. Respectfully submitted, ____________________________________ David A. Schulman Attorney at Law 1801 East 51st Street, Suite 365-474 Austin, Texas 78723 Tel. 512-474-4747 Fax: 512-532-6282 zdrdavida@davidschulman.com State Bar Card No. 17833400 Attorney for Harold James Harris Certificate of Compliance and Delivery This is to certify that: (1) this document, created using WordPerfect™ X7 software, contains 327 words, excluding those items permitted by Rule 9.4 (i)(1), Tex.R.App.Pro., and complies with Rules 9.4 (i)(2)(B) and 9.4 (i)(3), Tex.R.App.Pro.; and (2) on May 4, 2015, a true and correct copy of the above and foregoing “Motion for Extension of Time To File Appellant’s Brief on Appeal” was transmitted via the eService function on the State’s eFiling portal, to Laura E. Durbin (laura.durbin@bexar.org), cousel of record for the State of Texas. ______________________________________ David A. Schulman