ACCEPTED
01-15-00268-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/4/2015 5:11:40 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00268-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
For the 12/4/2015 5:11:40 PM
First District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston
♦
No. 1450059
In the 177th District Court
Of Harris County, Texas
♦
TONI TAVAREZ
Appellant
v.
THE STATE OF TEXAS
Appellee
♦
STATE’S SECOND MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
♦
To the Honorable Court of Appeals:
The State of Texas, pursuant to TEX. R. APP. P. 2 & 10.5, moves for an
extension of time in which to file its appellate brief. The following facts are
relevant:
1. The appellant was indicted for murder. (CR 8). The appellant pleaded
not guilty, but a jury found her guilty as charged. (CR 329, 340). The
jury assessed punishment at fifty years’ confinement. (CR 339, 340).
The trial court certified the appellant’s right of appeal, and the
appellant filed a timely notice of appeal. (CR 313, 343).
2. The State’s brief is due on December 4, 2015. The State requests a
30-day extension of time in which to file its brief.
3. This is the State’s second request for extension.
4. The following facts are relied upon to show good cause for an
extension of time to allow the State to file its brief:
a. Since this Court granted the State’s first motion for extension
on November 4, 2015, the undersigned attorney has worked on
the following matters:
1. Christopher Dewa Washington
No. 01-14-00366-CR
Oral argument held November 4, 2015
Motion for rehearing filed November 23, 2015
2. Augustus Mitchell
No. 01-15-00397-CR
Brief filed November 6, 2015
3. Joseph Juan Facundo
No. 01-15-00279-CR
Brief filed November 25, 2015
4. Leiroi Mikele Daniels
No. 14-15-00111-CR
Brief filed December 3, 2015
WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted,
/s/ C.A. Morgan
CLINTON A. MORGAN
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
713.274.5826
morgan_clinton@dao.hctx.net
TBC No. 24071454
CERTIFICATE OF SERVICE
I certify that I have requested that efile.txcourts.gov electronically serve
a copy of this motion to:
Daucie Schindler
daucie.schindler@pdo.hctx.net
/s/ C.A. Morgan
CLINTON A. MORGAN
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
713.274.5826
morgan_clinton@dao.hctx.net
TBC No. 24071454
Date: December 4, 2015