ACCEPTED
14-14-00306-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
3/31/2015 6:56:15 PM
CHRISTOPHER PRINE
CLERK
Nos. 14-14-00306-CR, 14-14-00307-CR, 14-14-00308-CR, 14-14-00309-CR, &
14-14-00310-CR
FILED IN
14th COURT OF APPEALS
In the HOUSTON, TEXAS
Court of Appeals 3/31/2015 6:56:15 PM
For the CHRISTOPHER A. PRINE
Clerk
Fourteenth District of Texas
At Houston
Nos. 1909495, 1909496, 1909497, 1909498, & 1909499
In County Criminal Court at Law Number Six
Of Harris County, Texas
ERIC L. BAUMGART
Appellant
V.
THE STATE OF TEXAS
Appellee
STATE’S THIRD MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE APPELLATE BRIEF
TO THE HONORABLE COURT OF APPEALS:
THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 10.1, 10.5(b) and
38.6(d), moves for an extension of time within which to file its appellate brief. In
support of its motion, the State submits the following:
1. Appellant was convicted of five counts for the offense of violating
the Private Security Act and sentenced to two years of community
supervision.
2. Appellant filed written notice of appeal on March 13, 2014.
3. Appellant filed his brief on December 1, 2014.
4. The State’s reply brief is due on March 31, 2015.
5. The State seeks an extension until April 30, 2015, to file its brief.
6. This is the State’s third request for an extension in this case. The
State’s first extension was sought on account of the State not having
timely received a copy of appellant’s brief.
7. The following facts are relied upon to show good cause for the
requested extension:
My completion of this brief has been delayed by my
completion of three other appellate briefs over the past
five weeks, as well as by my preparation for and
presentation of an oral argument before this Court. I also
have four other appellate briefs due in the coming month.
Additionally, I missed several days of work over the past
month due to my spouse’s recent surgery.
I am currently working on the brief for this case and
intend to continue to work on it until it is completed, to
the exclusion of all other cases assigned to me.
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WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted,
/s/ Dan McCrory
DAN MCCRORY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1901
(713) 755-5826
TBC No. 13489950
Mccrory_daniel@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been mailed to
the following email address via TexFile:
Renato Santos, Jr.
Attorney at Law
Renato.santos3@att.net
/s/ Dan McCrory
DAN MCCRORY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1901
(713) 755-5826
TBC No. 13489950
Date: March 31, 2015
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