ACCEPTED
01-15-00487-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
10/22/2015 11:41:27 AM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00487-CR
IN THE COURT OF APPEALS FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
FIRST DISTRICT 10/22/2015 11:41:27 AM
CHRISTOPHER A. PRINE
Clerk
HOUSTON, TEXAS
NO. 1416994
IN THE TRIAL COURT
230TH JUDICIAL DISTRICT
HARRIS COUNTY, TEXAS
FREDIS MAURICIO FLORES § APPELLANT
VS. §
THE STATE OF TEXAS § APPELLEE
MOTION FOR EXTENSION OF TIME
FOR FILING APPELLANT'S BRIEF
ALLEN C. ISBELL
2016 Main St., Suite 110
Houston, Texas 77002
713/236-1000
Fax: 713/236-1809
STATE BAR NO. 10431500
Email:allenisbell@sbcglobal.net
COUNSEL ON APPEAL
TO THE HONORABLE COURT OF APPEALS:
COMES NOW FREDIS MAURICIO FLORES, appellant, by and through
his retained counsel on appeal, and respectfully requests this Honorable
Court grant an Extension of Time for Filing an Appellant's Brief. The present
date for filing the Brief is October 26, 2015, and it is respectfully requested
that said time be extended until November 25, 2015. For cause, appellant
would show the Court as follows:
I.
On May 14, 2015, appellant was convicted of Driving While Intoxicated
(3rd Offender), in the 230th District Court of Harris County, Texas entitled The
State of Texas vs. FREDIS MAURICIO FLORES, in Cause Number 1416994
and was sentenced to four (4) years confinement in the Texas Department of
Criminal Justice, Institutional Division. No Motion for New Trial was filed and
written Notice of Appeal was given May 21, 2015.
II.
Counsel is unable to timely file the Brief within the time period from the
first extension of filing the Reporter’s Record for the following reasons:
1. Counsel is preparing for the following Trials:
• State vs. Simon, No. 1391357 (Capital Murder)(set to begin
October 22, 2015);
c:\appeals\flores\extension 2
• State vs. Aguilar, No. 1370058 (Murder).
2. Counsel has recently represented the following in court: State vs.
Aguilar, No. 1370058; State vs. Allen, Nos. 1475254 & 1403306;
State vs. Caplan, No. 1449686; State vs. Collins, No. 1468713;
State vs. Cornelius, No. 1483722; State vs. Dornes, No.
1477372; State vs. Hastings, No. 1464287; State vs. Hornsby,
Nos. 1455466, 1455467 & 1455768; State vs. Johnson, No.
1485392; State vs. Joyner, No. 1358039; State vs. Koch, No.
1473727; State vs. Landon, No. 1370845; State vs. Nuñez-
Reyes, No. 1476299; State vs. Palmer, No. 1419391; State vs.
Sanfelippo, No. 1479165; State vs. Simon, No. 1391357; State vs.
Taylor, No. 1481280; State vs. Vallier, No. 1480767; State vs.
Zumoff, No. 1485229;
III.
Counsel feels that if the additional time is granted, the Brief in this cause
will be filed timely.
IV.
This is the second (2nd) extension requested.
V.
This motion is urged at the first opportunity as appellant will suffer
irremediable harm if it is not granted.
WHEREFORE, PREMISES CONSIDERED, appellant prays that this
Honorable Court grant this extension of time in which to file the Appellant's
Brief until November 25, 2015.
c:\appeals\flores\extension 3
Respectfully submitted,
/s/ Allen C. Isbell
ALLEN C. ISBELL
2016 Main St., Suite 110
Houston, Texas 77002
713/236-1000
Fax No. 713/236-1809
STATE BAR NO. 10431500
Email: allenisbell@sbcglobal.net
COUNSEL ON APPEAL
Certificate of Service
I hereby certify that on this 22nd day of October, 2015, a true and correct
copy of the foregoing motion was sent to the District Attorney's Office,
Appellate Division, and to Mr. Fredis Mauricio Flores, appellant.
/s/ Allen C. Isbell
ALLEN C. ISBELL
Certificate of Compliance
The undersigned attorney on appeal certifies this motion is computer
generated and consists of 561 words. Counsel is relying on the word count
provided by the Word Perfect computer software used to prepare the motion.
/s/ Allen C. Isbell
ALLEN C. ISBELL
c:\appeals\flores\extension 4