Charles Roberts v. State ( 2015 )

ACCEPTED
14-14-00874-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
6/4/2015 1:40:05 PM
CHRISTOPHER PRINE
CLERK
No. 14-14-00874-CR
In the FILED IN
Court of Appeals 14th COURT OF APPEALS
HOUSTON, TEXAS
For the 6/4/2015 1:40:05 PM
Fourteenth Judicial District of Texas CHRISTOPHER A. PRINE
At Houston Clerk

No. 1381559
In the 177th District Court of
Harris County, Texas

CHARLES ROBERTS
Appellant
v.
THE STATE OF TEXAS
Appellee

STATE’S MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE APPELLATE BRIEF

TO THE HONORABLE COURT OF APPEALS OF TEXAS:
COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.1(a)
and 38.6(d) of the Texas Rules of Appellate Procedure, and files this motion for
extension of time in which to file the State’s brief in this case, and, in support thereof,
presents the following:
1. In the 177th District Court of Harris County, Texas, in The State of Texas v.
Charles Roberts, Cause Number 1381559, appellant was charged with murder.
2. Appellant was sentenced to fifty years incarceration.
3. The State’s brief was due on June 4, 2015.
5. An extension of time in which to file the State’s brief is requested until July 6,
2015.
6. Two previous extension has been requested by the State.
7. The facts relied upon to explain the need for this extension are:
a) The undersigned attorney was assigned this case in March 2014;
b) Since the undersigned attorney was assigned this case, the attorney finished
writing the State’s briefs in the following cases:
(1) Cause Number 01-14-00421-CR, Eric Dewayne Small, Appellant v. The State
of Texas, Appellee, which involves six points of error and eight volumes of
the reporter’s record;
(2) Cause Number 01-14-00421-CR, Brodies E. Myles, Appellant v. The State of
Texas, Appellee, which involves one point of error and four volumes of
the reporter’s record;
(3) Cause Number 14-14-00473-CR, Jimmy Earl Van-Cleave, Appellant v. The
State of Texas, Appellee, which involves two points of error and four
volumes of the reporter’s record;
(4) Cause Number 14-14-00910-CR, Ex parte Erik Montes de Oca-Orozco,
which involved two points of error and one volume of the reporter’s
record and that was filed on April 15, 2015;
(5) Cause Number 01-14-00900-CR, Felicity Burris, Appellant v. The State of
Texas, Appellee, which involved one point of error and two volumes of
the reporter’s record; and
(6) Cause Number 01-14-00748-CR, James Lee Skinner, Appellant v. The State
of Texas, Appellee, which involved three points of error.
c) The undersigned attorney was also recently preparing for oral argument in
Cause Number 01-13-00931-CR, Melissa Dromgoole, Appellant v. The State of
Texas, Appellee, that was held on April 8, 2015.
d) The undersigned attorney is also currently engaged in the preparation of the
State’s Brief in the following appellate cause numbers:
(1) Cause Number 01-14-00772-CR, Thanh Hoang, Appellant v. The State of
Texas, Appellee, which involves one point of error; and
(2) Cause Number 01-14-00885-CR, Abner Washington, Appellant v. The State
of Texas, Appellee, which involves one point of error.
e) Additionally, the undersigned attorney has also been out of the office last week
from the flooding in Houston and from attending the Conference on Criminal
Appeals in Austin.
WHEREFORE, the State prays that this Court will grant an extension of time until
July 6, 2015 in which to file the State’s brief in this case.
Respectfully submitted,
/s/ Carly Dessauer
________________________________________________________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served to
appellant’s attorney on June 4, 2015 through TexFile:
Angela L. Cameron
Assistant Public Defender, Harris County
1201 Franklin Street, 13th Floor
Houston, Texas 77002
angela.cameron@pdo.hctx.net
/s/ Carly Dessauer
________________________________________________________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
curry_alan@dao.hctx.net
Date: June 4, 2015