ACCEPTED
14-15-00503-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
8/31/2015 3:11:51 PM
CHRISTOPHER PRINE
CLERK
No. 14-15-00503-CR
In the FILED IN
Court of Appeals 14th COURT OF APPEALS
HOUSTON, TEXAS
For the 8/31/2015 3:11:51 PM
Fourteenth Judicial District of Texas CHRISTOPHER A. PRINE
At Houston Clerk
No. 1311548
In the 208th District Court of
Harris County, Texas
THE STATE OF TEXAS
Appellant
v.
PASTOR ISREAL DIAZ-BONILLA
Appellee
STATE’S MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE APPELLATE BRIEF
TO THE HONORABLE COURT OF APPEALS OF TEXAS:
COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.1(a)
and 38.6(d) of the Texas Rules of Appellate Procedure, and files this motion for
extension of time in which to file the State’s brief in this case, and, in support thereof,
presents the following:
1. In the 208th District Court of Harris County, Texas, in The State of Texas v.
Pastor Isreal Diaz-Bonilla, Cause Number 1311548, appellee was charged with
engaging in organized criminal activity.
2. Appellee pleaded guilty and was sentenced to thirty-five years incarceration.
However, the trial court granted appellee’s motion for new trial.
3. The State filed a timely notice of appeal.
4. The State’s brief was due on August 31, 2015.
5. An extension of time in which to file the State’s brief is requested until
September 8, 2015.
6. Two previous extensions have been requested by the State.
7. The facts relied upon to explain the need for this extension are:
a) The undersigned attorney has been unable to finish writing the State’s brief
in this case since the last requested extension of time was granted by this
Court.
b) The undersigned attorney has finished writing the State’s briefs in the
following case since being assigned to this case:
(1) Cause Number 14-14-00874-CR, Charles Roberts, Appellant v. The State of
Texas, Appellee, filed on July 9, 2015;
(2) Cause Number 04-14-01010-CR, Marcus D. Jackson, Appellant v. The State
of Texas, Appellee, filed on July 29, 2015;
(3) Cause Number 14-14-01008-CR, Mary Kuol, Appellant, v. The State of
Texas, Appellee, filed on July 30, 2015; and
(4) and Cause Number 14-15-00405-CR, Jermaine Lewis, Appellant, v. The State
of Texas, Appellee.
c) The undersigned attorney is also currently engaged in the preparation of the
State’s Brief in the following appellate cause numbers:
(1) Cause Number 01-14-00885-CR, Abner Washington, Appellant v. The State
of Texas, Appellee;
(2) Cause Number 14-14-00375-CR, Frank Distefano, Appellant, v. The State of
Texas, Appellee; and
(3) Cause Numbers 01-15-00324-CR and 01-15-00325-CR, Astin Chavers
Clark, Appellant, v. The State of Texas, Appellee.
WHEREFORE, the State prays that this Court will grant an extension of time until
September 8, 2015 in which to file the State’s brief in this case.
Respectfully submitted,
/s/ Carly Dessauer
________________________________________________________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served to
appellant’s attorney on August 31, 2015 through TexFile:
Randy Schaffer
Attorney at Law
1301 McKinney, Suite 3100
Houston, Texas 77010
noguilt@swbell.net
/s/ Carly Dessauer
________________________________________________________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
curry_alan@dao.hctx.net
Date: August 31, 2015