Andreas Marcopoulos v. State

ACCEPTED 01-15-00317-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/23/2015 11:44:37 AM CHRISTOPHER PRINE CLERK Cause No. 01-15-00317-CR IN THE COURT OF APPEALS FILED IN 1st COURT OF APPEALS FOR THE HOUSTON, TEXAS FIRST JUDICIAL DISTRICT OF TEXAS 12/23/2015 11:44:37 AM AT HOUSTON CHRISTOPHER A. PRINE Clerk ANDREAS MARCOPOULOS, Appellant v. THE STATE OF TEXAS, Appellee. Appeal from Cause No. 1440970 In the 248th District of Harris County, Texas ____________________________________________________________________ APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF TO THE HONORABLE JUSTICES OF THE FIRST DISTRICT COURT OF APPEALS: Appellant, ANDREAS MARCOPOULOS, by and through his counsel of record, CARMEN ROE, files this Appellant’s Motion for Extension of Time to File Reply Brief and in support shows this Court the following: I. Appellant was charged with the felony offense of possession of a controlled substance in Cause No. 1440970 in the 248th District Court of Harris County Texas. Appellant filed a pretrial motion to suppress that was denied. Subsequently, Appellant pled guilty and was placed on deferred adjudication probation for three (3) years. On March 26, 2015, Appellant filed a notice of appeal and the trial court’s certification of the right to appeal his pretrial orders. II. Appellant’s Brief was filed October 21, 2015 and the State’s Brief was filed December 3, 2015. Appellant’s Reply Brief is currently due on December 23, 2015. III. Appellant requests an extension of thirty (30) days until January 22, 2016 to file its reply brief. Counsel requests the additional time because the following briefs are due in the courts of appeal: State v. Derek Johnson, State v. Jordan Nichols, State v. Mashood Uddin, and State v. Brian Vanorman. For these reasons, Counsel has been unable to submit its reply brief on the due date and hereby requests an extension of time. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court extend the time for filing Appellant’s Reply Brief in this cause until January 22, 2016. RESPECTFULLY SUBMITTED, /s/ Carmen Roe _________________________________ CARMEN ROE CARMEN ROE LAW FIRM SBN: 24048773 440 Louisiana, Suite 900 Houston, Texas 77002 713.236.7755 Phone 713.236.7756 Fax carmen@carmenroe.com ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing was served to the Harris County District Attorney, Appellate Division, 1201 Franklin Street, Houston, Texas 77002, on December 23, 2015. /s/ Carmen Roe _____________________________ CARMEN ROE