Travis Marcellaus Edwards v. State

ACCEPTED 01-15-00416-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 10/26/2015 10:50:27 AM CHRISTOPHER PRINE CLERK IN THE FIRST COURT OF APPEALS OF TEXAS FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS TRAVIS M. EDWARDS § 10/26/2015 10:50:27 AM § CHRISTOPHER A. PRINE VS. § CASE NOs. 01-15-00416-CR,Clerk § 01-15-00417-CR, & 01-15-00418-CR THE STATE OF TEXAS § MOTION TO EXTEND TIME IN WHICH TO FILE APPELLATE BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: NOW COMES, TRAVIS EDWARDS, appellant in the above-styled and numbered causes, by and through his attorney of record, Daucie Schindler, and respectfully moves the Court for an extension of time within which to file the appellate brief, and for cause would show the Court as follows: I. Mr. Edwards was charged with the felony offense of aggravated robbery in cause number 1443321, the felony offense of felon in possession of a firearm in cause number 1443322 and the felony offense of aggravated assault of a public servant in cause number 1353154. On, April 23, 2015, Mr. Edwards was convicted as charged and sentenced by the court to thirty (30) years imprisonment in the Institutional Division of the Texas Department of Criminal Justice for the aggravated robbery, ten (10) years in the Institutional Division of the Texas Department of Criminal Justice for the felon in possession of a firearm, and thirty (30) years in the Institutional Division of the Texas Department of Criminal Justice for the aggravated assault all to run concurrently. II. Mr. Edwards filed timely notice of appeal and undersigned counsel, of the Harris County Public Defender’s Office was appointed to represent him on April 24, 2015. III. The appellate brief is due to be filed with the Court on or before October 26, 2015. One previous extension has been requested. IV. Undersigned counsel has been working simultaneously on appeal in Wiggins v. State, Rodriguez v. State, Tavarez v. State, Earvin v. State, Fletcher v. State, Williams v. State, and Marks v. State. Counsel is diligently working on the brief in this case, but requests additional time to research and confer with the client. V. This request is made not to delay the proceedings, but to ensure the Mr. Edwards is adequately represented. WHEREFORE, PREMISES CONSIDERED, Mr. Edwards respectfully prays that this motion be granted and that the Court permits an extension of time until November 25, 2015, to file the appellate brief. Respectfully Submitted, ALEXANDER BUNIN Chief Public Defender Harris County Texas /s/ Daucie Schindler __________ DAUCIE SCHINDLER Assistant Public Defender Harris County Texas 1201 Franklin, 13th Floor Houston, Texas 77002 (713) 274-6717 (713) 368-9278 Fax Daucie.Schindler@pdo.hctx.net Attorney for Appellant, TRAVIS M. EDWARDS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Appellant’s Motion to Extend Time Within Which to File Appellate Brief was e-mailed to the Appellate Division of the Harris County District Attorney’s Office on this 26th day of October, 2015. /s/ Daucie Schindler__________ DAUCIE SCHINDLER