in the Matter of David Christopher Hesse ( 2015 )

ACCEPTED
01-15-00401-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/8/2015 4:58:18 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00401-CR
§ IN THE FIRST DISTRICT
FILED IN
1st COURT OF APPEALS
IN THE MATTER OF HOUSTON, TEXAS
§ COURT OF7/8/2015
APPEALS 4:58:18 PM
DAVID CHRISTOPHER HESSE CHRISTOPHER A. PRINE
Clerk
§ HOUSTON, TEXAS
STATE’S FIRST MOTION FOR EXTENSION OF TIME
TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS:
Pursuant to Texas Rule of Appellate Procedure 38.6(d), the State, by and
through its Fort Bend County District Attorney, asks this Court to grant an extension
of time to submit its appellate brief in the above-referenced cause.
Pursuant to Texas Rule of Appellate Procedure 10.5(b), the State provides the
following information:
Current Deadline: July 8, 2015
Length of Extension Sought: Fifteen days to July 23, 2015
Number of Previous Extensions: None
Facts reasonably explaining the need for an extension:
In the last thirty days, the undersigned assistant district attorney has been
working on the State’s brief in the appeal from the convictions for aggravated robbery
and fifty-year sentences involving an appellant, who was fourteen years old when
these crimes were committed, in Gentry v. State, Nos. 01-14-00335-CR and 01-14-
1
00336-CR due on July 10, 2015, on an extended deadline, no further extensions. The
undersigned committed to make this appeal her priority. The undersigned also was
out-of-state for a pre-planned, pre-paid family reunion June 11-20, 2015.
Barring unforeseen circumstances, the State will not ask for further extension
of its deadline. The State asks for an extension of time not for delay only, but to see
that justice is done.
Respectfully submitted,
John F. Healey, Jr.
SBOT # 09328300
District Attorney, 268th Judicial District
Fort Bend County, Texas
/s/ Gail Kikawa McConnell
Gail Kikawa McConnell
SBOT # 11395400
Assistant District Attorney
301 Jackson Street, Room 101
Fort Bend County, Texas 77469
(281) 238-3205 / (281) 238-3340 (fax)
Gail.McConnell@fortbendcountytx.gov
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing State's motion was served on July
8, 2015, through the electronic filing manager or by email on L.T. “Butch” Bradt,
Attorney for Appellant.
/s/ Gail Kikawa McConnell
Gail Kikawa McConnell
2