ACCEPTED
14-14-00568-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
3/31/2015 10:11:13 AM
CHRISTOPHER PRINE
CLERK
CAUSE NO. 14-14-00568-CR
FILED IN
14th COURT OF APPEALS
MARCUS BROOKS, § IN THE COURT HOUSTON,
OF APPEALS TEXAS
APPELLANT § 3/31/2015 10:11:13 AM
§
CHRISTOPHER A. PRINE
VS. § 14TH JUDICIAL DISTRICT
Clerk
§
THE STATE OF TEXAS, §
APPELLEE § AT HOUSTON, TEXAS
CASE NO. 1408106
THE STATE OF TEXAS § IN THE DISTRICT COURT OF
§
VS. § HARRIS COUNTY, TEXAS
§
MARCUS BROOKS § 230TH JUDICIAL DISTRICT
APPELLANT’S THIRD MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW MARCUS BROOKS, appellant, by and through his attorney of record,
KURT B. WENTZ, who files this Appellant’s Third Motion for Extension of Time to File
Appellant’s Brief and in support thereof would show this Court as follows:
I.
The appellant has been found guilty of injury to a child under the age of 15 and sentenced
to confinement in the Institutional Division of the Texas Department of Criminal Justice.
II.
On August 5, 2014 the reporter’s record was received by this Court.
The appellant’s brief was due on or about September 6, 2014.
III.
This Court has granted two prior requests for extension of time to file the appellant's
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brief. The date of the most recent request was to March 15, 2015.
IV.
Counsel's failure to submit the appellant's brief is not the result of indifference or neglect.
Other cases have consumed counsel's time and ability to complete the appellant's brief. These
other cases include:
A. The trial of an aggravated sexual assault in a case entitled The State of Texas v.
Richard Owings.
B. The necessity of preparing for three aggravated robbery cases in a case entitled The
State of Texas v. Enitor Cole.
C. The need to prepare for a complex organized crime case entitled The State of Texas v.
Stephanie Atak.
D. Counsel's recent appointment to two non-death capital murder cases.
V.
A request for an extension of time to May 15, 2015 is requested.
VI.
This request is not intended for the purposes of delay but only so that justice may be
done.
WHEREFORE, PREMISES CONSIDERED, the appellant prays that the Court grant this
motion in all things.
Respectfully submitted,
/s/Kurt B. Wentz____________________________
KURT B. WENTZ
5629 Cypress Creek Parkway, Suite 115
Houston, Texas 77069
Phone: 281/587-0088
e-mail: kbsawentz@yahoo.com
State Bar No. 21179300
ATTORNEY FOR APPELLANT
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CERTIFICATE OF SERVICE
I, Kurt B. Wentz, hereby certify that a true and correct paper copy of the appellant's Third
Motion for Extension of Time to File Appellant's Brief was served on the Assistant District
Attorney for Harris Count, Texas presently handling this Cause on the 31st day of March, 2015.
/s/Kurt B. Wentz___________________________
KURT B. WENTZ
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