Blake Anthony Monakino v. State

ACCEPTED 01-14-00361-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/14/2015 9:49:54 AM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS OF TEXAS FIRST JUDICIAL DISTRICT FILED IN BLAKE ANTHONY MONAKINO § 1st COURT OF APPEALS HOUSTON, TEXAS § 12/14/2015 9:49:54 AM VS. § CASE NO. 01-14-00361-CR CHRISTOPHER A. PRINE § Clerk THE STATE OF TEXAS § MOTION TO EXTEND TIME TO FILE BRIEF TO THE HONORABLE JUSTICES OF THIS COURT: Appellant asks the Court to extend time to file his brief from December 9, 2015, for 30 days for the following reasons: 1. The Court granted appellant’s motion to abate for a complete record on April 16, 2015. On October 9, 2015 the appeal was reinstated with a due date of November 9, 2015. 2. When the case was reinstated, counsel was working on Carter v. State, 01-14- 01006-CR, which was filed on November 6, 2015. In addition, counsel is working on meeting deadlines on five cases due between this date and December 1, 2015. 4. Counsel has submitted two briefs since the previous extension request and has four imminent deadlines as of this writing: Cameron v. State, 14-15-00447-CR, due December 14, 2015, Bonds v. State, 14-15-00688-CR, due December 15, 2015; Humphrey v. State, 14-150026-CR (felony murder, with hearing on a motion for new trial), due December 18, 2015; and Sanchez v. State, 01-15-00609-CR, due December 23, 2015; as well as the instant case and despite due diligence has been unable to fully review the new information obtained during the abatement. 5. As this Court is probably aware, this office has been short of three appellate lawyers for several months. Two new lawyers have now begun work, one as of November 30 and the other as of December 7, 2015; they are helping with the divisions backlog but it will take a month or so before everyone has caught up. This writer will be using the upcoming holidays to expedite this process and asks the Court for its patience. In view of the forgoing, we request an extension of 30 days from December 9, 2015 to January 9, 2016. Respectfully submitted, ALEXANDER BUNIN Chief, Harris County Public Defender’s Office /s/ Melissa Martin _________________________________ MELISSA MARTIN Assistant Public Defender TX. Bar No. 24002532 1201 Franklin St., 13th Fl. Houston, TX 77002 email: melissa.martin@pdo.hctx.net 713/274-6709 Fax 713/437-4319 CERTIFICATE OF SERVICE I certify that a copy of the foregoing motion was electronically served on the Harris County District Attorney’s office on December 14, 2015. /s/ Melissa Martin __________________________ Melissa Martin