in the Matter of M. I. S., a Juvenile

ACCEPTED 01-14-00684-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 10/21/2015 3:10:22 PM CHRISTOPHER PRINE CLERK No. 01-14-00684-CV In the FILED IN Court of Appeals 1st COURT OF APPEALS For the HOUSTON, TEXAS 10/21/2015 3:10:22 PM First District of Texas At Houston CHRISTOPHER A. PRINE Clerk  No. 2013-05802J In the 313th District Court Of Harris County, Texas  IN THE MATTER OF M.I.S. Appellant  STATE’S FOURTH MOTION FOR EXTENSION OF TIME WITHIN 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) and 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 found to have engaged in delinquent conduct by committing the offense of aggravated robbery. 2. The judge committed appellant to the custody of the Texas Juvenile Justice Department for 10 years. 3. Appellant filed written notice of appeal on August 14, 2014. 4. Appellant filed his brief on May 4, 2015. 5. The State’s reply brief is due on October 5, 2015. 6. The State seeks an extension until October 21, 2015, to file its brief. 7. The State’s brief was filed today. 8. This is the State’s fourth request for an extension in this case. 9. The following facts are relied upon to show good cause for the requested extension: My completion of this brief has been delayed by my work on two other appellate briefs this past month, as well as by my recent preparation for and presentation of an oral argument. 2 WHEREFORE, the State prays that this Court will grant the requested extension. Respectfully submitted, /s/ Dan McCrory DAN MCCRORY Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1901 (713) 755-5826 TBC No. 13489950 Mccrory_daniel@dao.hctx.net CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument has been sent to the following email addresses via TexFile: Cheri Duncan Amalia Beckner Assistant Public Defenders Cheri.duncan@pdo.hctx.net amaliabeckner@pdo.hctx.net /s/ Dan McCrory DAN MCCRORY Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1901 (713) 755-5826 TBC No. 13489950 Date: October 21, 2015 3