PD-0587-1
COURT OF CRIMINAL APPEAL
FILED IN
AUSTIN, TEXA
COURT OF CRIMINAL APPEALS Transmitted 11/13/2015 2:33:53 Pf
Accepted 11/13/2015 2:35:58 Pf
November 13, 2015 ABEL ACOST
No. PD-0587-15
CLER
ABELACOSTA, CLERK In the
v_.uart of Criminal Appeals of Texas
At Austin
No. 01-14-00501-CR
In the Court of Appeals for the
First District of Texas
At Houston
ANDREW OLEVIA JONES
Appellant
v.
THE STATE OF TEXAS
Appellee
STATE'S MOTION FOR EXTENSION OF TIME
FOR FILING OF BRIEF ON APPELLANT'S
PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE COURT OF CRIMINAL APPEALS OF TEXAS:
COMES NOW THE STATE OF TEXAS, in accordance with Rules
10.5(b)(1) and 70.3 of the Texas Rules of Appellate Procedure, and files this motion
for extension of time in which to file the State's brief on the appellant's petition for
discretionary review in this cause, and, in support thereof, presents the following:
1. In the 338th District Court of Harris County, Texas, in cause number
1390646, on May 14, 2014, Appellant was convicted in The State of Texas v.
Andrew Olevia Jones.
2. For the offense of assault of a family member, Appellant's punishment was
assessed at 15 years in prison.
3. A written notice of appeal was filed on June 4, 2014.
4. The First Court of Appeal dismissed Appellant's appeal on April 14, 2015.
5. The appellant's petition for discretionary review was granted by this Court
on August 26, 2015.
6. The appellant's brief in support of the petition for discretionary review was
filed with this Court on October 9, 2015.
7. An extension of time in which to file the State's brief on the appellant's
petition for discretionary review is requested until November 13, 2015.
8. No previous extensions have been requested by the State.
9. The facts relied upon to explain the need for this extension are:
The undersigned attorney is the Chief of the Appellate Division of the
Harris County District Attorney's Office, and, in addition to the
numerous duties accorded to his position, he is assigned to the appeal in
the appellant's case.
WHEREFORE, the State prays that this Court will grant an extension of time
until November 13, 2015 in which to file the State's brief on the appellant's petition
for discretionary review in this case.
Respectfully submitted,
Isi /fa* &my
ALAN CURRY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 05263700
curry_alan@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been mailed to
the appellant's attorneys at the following addresses on November 13, 2015:
Melissa Martin
Attorney at Law
1201 Franklin, 13th Floor
Houston, Texas 77002
Isi /tOut @cmy
ALAN CURRY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 05263700
curry_alan@dao.hctx.net
Date: November 13, 2015
Jones, Andrew Olevia
Combined Opinion