ACCEPTED
01-15-00272-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
9/3/2015 4:38:13 PM
CHRISTOPHER PRINE
CLERK
01-15-00272-CR
In the
Court of Appeals FILED IN
For the 1st COURT OF APPEALS
HOUSTON, TEXAS
First District of Texas 9/3/2015 4:38:13 PM
At Houston CHRISTOPHER A. PRINE
Clerk
No. 1457961
In the 184th District Court of
Harris County, Texas
HUGO ADOLFO ALANIS
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 number 1457961,
the State of Texas v. Hugo Adolfo Adolfo, appellant, was convicted of possession
of a controlled substance.
2. He was assessed punishment of confinement for 15 years in the Institutional
Division of the Texas Department of Criminal Justice.
3. The State’s brief is due on September 3, 2015.
4. An extension of time in which to file the State’s brief is requested until
October 5, 2015.
5. No previous extension has 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 01-14-
00444-CR, 14-14-00831-CR, and 01-14-01032/3-CR. Also, I prepared for and
participated in a contempt hearing against Sondra Humphrey, the former
official court reporter for County Court at Law No. 8 of Harris County, Texas.
Additionally, I answer trial court questions from other prosecutors 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 October 5, 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 September 3, 2015:
Scott Ramsey
1212 Durham Drive
Houston, TX 77007
/s/ Abbie Miles
Abbie Miles
Assistant District Attorney
Harris County, Texas
Date: September 3, 2015