ACCEPTED
14-15-00252-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
10/23/2015 9:24:42 AM
CHRISTOPHER PRINE
CLERK
No. 14-15-00252-CR
In the FILED IN
Court of Appeals 14th COURT OF APPEALS
HOUSTON, TEXAS
For the 10/23/2015 9:24:42 AM
Fourteenth District of Texas CHRISTOPHER A. PRINE
At Houston Clerk
No. 1390666
In the 351st District Court
Of Harris County, Texas
JUAN JOSE QUINTERO
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 and in its motion, would show
the Court the following:
1. The State charged the appellant with murder by intentionally and
knowingly causing the death of Ronald Stelly, and the jury found the
appellant guilty (CR – 22, 142; 4 RR 47). The trial court sentenced
him in accordance with the jury’s verdict to life in prison in the Texas
Department of Criminal Justice, Institutional Division (CR – 149, 151-
52; 5 RR 52). The appellant timely notice of appeal, and the trial court
certified that he had the right to appeal (CR – 154-56). The State’s
brief is due on October 23, 2015. This is the State’s second request for
an extension. The following facts are relied upon to show good cause
for an extension of time to allow the State to file its brief:
a. The record in this case is over thirty-four megabytes in length split
over seven volumes and will take some time to process. The
appellant brings two points of error. The undersigned attorney has
read the record and is currently working to address the appellant’s
claims.
b. The undersigned attorney was involved in completing the
following written appellate projects since the appellant filed his
brief:
(1) Rafael Avellaneda v. The State of Texas
No. 14-14-00509-CR
Brief Filed August 17, 2015
Prepared Findings of Fact and Conclusions of Law
Filed Proposed Findings August 28, 2015
(2) Santos Cruz-Escalante v. The State of Texas
No. 01-15-00118-CR
Brief Filed August 27, 2015
(3) Jason Snavely v. The State of Texas
01-15-00185-CR
Brief Filed September 3, 2015
(4) Larry Torres v. The State of Texas
14-15-00155-158-CR
Brief Filed September 18, 2015
(5) Alfredo Lara v. The State of Texas
01-15-00472-CR
Brief Filed September 24, 2015
(6) Tyran Riley v. The State of Texas
14-15-00081-CR
Brief Filed October 6, 2015
(7) Christian A. Norris v. The State of Texas
01-15-00484-CR, 01-15-00485-CR
Brief Filed 10 13, 2015
Consequently, the undersigned attorney has been unable to
complete the State’s reply brief in this case in the time permitted
despite due diligence, and the requested extension of time is
necessary to permit the undersigned attorney to adequately
investigate, complete, and file the State’s appellate brief for this
cause. The State’s motion is not for purposes of delay, but so that
justice may be done.
WHEREFORE, the State prays that this Court will grant a thirty day extension of
time for the undersigned attorney to complete and file the State’s appellate brief in
this case.
Respectfully submitted,
/s/ Katie Davis
KATIE DAVIS
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
Davis_Katie@dao.hctx.net
TBC No. 24070242
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served by
efile.txcourts.gov to:
Niles Illich
701 Commerce, Suite 400
Dallas, TX 75202
972-802-1788/p
972-236-0088/f
Niles@appealstx.com
/s/ Katie Davis
KATIE DAVIS
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
Davis_Katie@dao.hctx.net
TBC No. 24070242
Date: October 23, 2015
Juan Jose Quintero v. State
Combined Opinion