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