Hugo Adolfo Alanis v. State

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