ACCEPTED
14-15-00498-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
10/6/2015 12:04:08 PM
CHRISTOPHER PRINE
CLERK
NO. 14-15-00498-CR
NO. 14-15-00499-CR
IN THE COURT OF APPEALS
FOR THE FOURTEENTH JUDICIAL DISTRICT14th COURT FILED IN
OF APPEALS
HOUSTON, TEXAS HOUSTON, TEXAS
___________________________________________ 10/6/2015 12:04:08 PM
CHRISTOPHER A. PRINE
Clerk
SCOTT NILES
V.
STATE OF TEXAS
__________________________________________
On Appeal from the Criminal Court at Law # 14
Harris County, Texas
Trial Court No. 2018917/2018918
__________________________________________
NILES’ FIRST MOTION FOR EXTENSION OF TIME
TO FILE APPELLATE BRIEF
__________________________________________
Scott Niles, through Neal Davis, files this first motion for an extension of time to
file his brief, showing specifically:
1. Appellant’s brief is due October 12, 2015.
2. Notice of appeal was filed on May 20, 2015. However, a timely motion for
new trial was also filed. The state filed a response to this motion on July 20, 2015, and
Niles responded on July 24, 2015. The trial court, after hearing arguments from both
parties, denied the motion for new trial on July 27, 2015.
3. This Court received the complete record on September 10, 2015, when
both the clerk’s and reporter’s record was filed.
4. Although this is a misdemeanor case the clerk’s record spans over 200
pages and the reporter’s record includes six volumes. Undersigned counsel has not had
adequate time to review the record in this case.
4. In addition to several criminal docket settings virtually every day in the
Harris County Criminal Justice Center, Undersigned has been working on and is
currently working on the following cases:
A. Undersigned counsel had been set for trial Monday, October 6,
2015, in Hays County in the case State v. Mandola. The case was recently
rescheduled but counsel had been preparing for the approaching trial.
B. Undersigned also had a sentencing hearing in State v. Charlie
Wilson, in the 228th District Court, on September 28, 2015. This was a
complex case and substantial preparation was required for the sentencing
hearing.
Niles respectfully requests a 60 day extension to file his appellate brief.
Respectfully submitted,
NEAL DAVIS LAW FIRM, PLLC
____/S/____________
Neal Davis
Texas Bar No. 24001117
917 Franklin Street, Suite 600
Houston, Texas 77002
Telephone: (713) 227-4444
Facsimile: (800) 760-7140
LAWYER FOR APPELLANT
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CERTIFICATE OF SERVICE
I certify that a copy of Niles’ FIRST MOTION FOR EXTENSION OF TIME TO
FILE APPELLATE BRIEF has been delivered via the e-file system to Harris County
Assistant District Attorney Alan Curry on October 6, 2015.
/s/
Neal Davis
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NO. 14-15-00498-CR
NO. 14-15-00499-CR
IN THE COURT OF APPEALS
FOR THE FOURTEENTH JUDICIAL DISTRICT
HOUSTON, TEXAS
___________________________________________
SCOTT NILES
V.
STATE OF TEXAS
__________________________________________
On Appeal from the Criminal Court at Law # 14
Harris County, Texas
Trial Court No. 2018917/2018918
__________________________________________
ORDER
__________________________________________
Upon considering Niles’ FIRST MOTION FOR EXTENSION OF TIME
TO FILE APPELLATE BRIEF —
It is ordered GRANTED.
Appellant’s brief is due on .
Signed _________ , 2015.
JUDGE PRESIDING
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