ACCEPTED
01-15-00444-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
10/9/2015 2:42:50 PM
CHRISTOPHER PRINE
CLERK
No. 1-15-00444-CR, 01-15-00445-CR, 01-15-00446-CR
In the
Court of Appeals FILED IN
1st COURT OF APPEALS
For the HOUSTON, TEXAS
First District of Texas 10/9/2015 2:42:50 PM
At Houston CHRISTOPHER A. PRINE
Clerk
No. 1378279, 1458347, 1458348
In 230th District Criminal Court
Harris County, Texas
BRANDON TODERICK JOHNSON, Appellant
V.
THE STATE OF TEXAS
Appellee
STATE’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE COURT OF APPEALS:
THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 2 & 10.5, moves for
an extension of time in which to file its appellate brief and in its motion, would
show the Court the following:
1. The appellant was charged with three aggravated robberies (RR1 3).
Appellant entered a plea of guilty to all three offenses (RR1 4). The jury
found him guilty as charged and assessed punishment in each case at 40
years in the Institutional Division of the Texas Department of Criminal
Justice (RR2 12). Appellant filed timely notice of appeal, and the court
certified his right to appeal (CR-156, 158).
2. The State’s brief was due October 8, 2015. The State hereby requests an
extension for the filing of the State’s brief until November 9, 2015.
3. The following facts are relied upon to show good cause for an extension
of time to allow the State to file its brief:
The State has been working on and has filed the following briefs in the last
thirty days.
Moreno v. State
1-15-00441-CR
State’s Brief filed September 18, 2015
Trigo v. State
01-15-00382-CR
State’s Brief filed September 24, 2015
Rodriguez v. State
1-15-00135-CR
State’s Brief due September 30, 2015
Furthermore, the undersigned attorney has been assigned the following
briefs in addition to the brief in this cause number.
Uddin v. State
14-15-00082-CR
State’s Brief due October 12, 2015
Briones v. State
01-14-00121-CR
State’s Brief due October 15, 2015
Dunn v. State
14-15-00340-CR
State’s Brief due October 26, 2015
4. This is the State’s first request for an extension of time to file its brief.
WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted,
/s/ Kimberly Stelter
KIMBERLY STELTER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
Stelter_Kimberly@dao.hctx.net
TBC No. 19141400
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served by
efile.txcourts.gov to:
Thomas Lewis
Attorney at Law
1602 Washington Ave.
Houston, TX 77007
/s/ Kimberly Stelter
KIMBERLY STELTER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
10/9/15