ACCEPTED
01-15-00054-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
9/30/2015 1:17:36 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00053-CR
No. 01-15-00054-CR FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
In the
9/30/2015 1:17:36 PM
Court of Appeals CHRISTOPHER A. PRINE
For the Clerk
First District of Texas
At Houston
♦
Nos. 1410122 & 1410123
In the 174th Criminal District Court
Of Harris County, Texas
♦
DAMIEN SCOTT
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:
THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 10.1, 10.5(b) & 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 charged with felon in possession of a firearm and
evading detention.
2. Appellant entered pleas of “guilty” after the trial court denied his
motion to suppress.
3. The court sentenced appellant to 6 years on the felon in possession of
a weapon charge and 4 years on the evading detention charge.
4. Appellant filed written notices of appeal on December 19, 2014.
5. Appellant’s brief was filed June 15, 2015.
6. The State’s brief was due July 15, 2015.
7. The State seeks an extension until today, September 30, 2015, to file
its brief.
8. The following facts are relied upon to show good cause for the
requested extension:
a. The undersigned attorney has filed 3 briefs in the last 30
days and has four more briefs due in the next 30 days.
b. The State’s motion is not for purposes of delay, but so that
justice may be done.
WHEREFORE, the State prays that this Court will grant the requested
extension until September 30, 2015.
Respectfully submitted,
/s/ Bridget Holloway
BRIDGET HOLLOWAY
Assistant District Attorney
Harris County, Texas
Harris County Criminal Justice Center
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
Texas Bar No. 24025227
holloway_bridget@dao.hctx.net
CERTIFICATE OF SERVICE
This certifies the undersigned attorney requested that a copy of this
document be served to appellant’s attorneys via TexFile at the following email on
September 30, 2015:
Melissa Martin
Attorney at Law
Email: melissa.martin@pdo.hctx.net
/s/ Bridget Holloway
BRIDGET HOLLOWAY
Assistant District Attorney
Harris County, Texas
Harris County Criminal Justice Center
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
Texas Bar No. 24025227
holloway_bridget@dao.hctx.net