Toni Tavarez v. State ( 2015 )

ACCEPTED
01-15-00268-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/6/2015 3:57:20 PM
CHRISTOPHER PRINE
CLERK
IN THE
FIRST COURT OF APPEALS
OF TEXAS FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
TONI TAVAREZ § 7/6/2015 3:57:20 PM
§ CHRISTOPHER A. PRINE
VS. § CASE NO. 01-15-00268-CR
Clerk
§
THE STATE OF TEXAS §
MOTION TO EXTEND TIME NWITHIN WHICH TO FILE APPELLATE
BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
NOW COMES, TONI TAVAREZ, appellant in the above-styled and
numbered cause, by and through her attorney of record, Daucie Schindler, and
respectfully moves the Court for an extension of time within which to file the
appellate brief, and for cause would show the Court as follows:
I.
Ms. Tavarez was charged with the felony offense of murder. On, March 12,
2015, Ms. Tavarez was convicted as charged and sentenced to fifty (50) years
imprisonment in the Institutional Division of the Texas Department of Criminal
Justice.
II.
Ms. Tavarez filed timely notice of appeal on March 12, 2015. Undersigned
counsel, of the Harris County Public Defender’s Office was appointed to represent
Ms. Tavarez on March 13, 2015.
III.
The appellate brief is due to be filed with the Court on or before July 6, 2015.
No previous extensions have been requested.
IV.
Undersigned counsel has been working simultaneously on appeal in State v.
Phillips, State v. Snavely, State v. Earvin, State v. Wiggins, and State v. Marks.
Counsel is diligently working on the brief in this case, but requests additional time to
research and confer with the client.
V.
This request is made not to delay the proceedings, but to ensure the Ms.
Tavarez is adequately represented.
WHEREFORE, PREMISES CONSIDERED, Ms. Tavarez respectfully prays that
this motion be granted and that the Court permits an extension of time until August
5, 2015, to file the appellate brief.
Respectfully Submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Daucie Schindler __________
DAUCIE SCHINDLER
Assistant Public Defender
Harris County Texas
1201 Franklin, 13th Floor
Houston, Texas 77002
(713) 274-6717
(713) 368-9278 Fax
Daucie.Schindler@pdo.hctx.net
Attorney for Appellant,
TONI TAVAREZ
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Appellant’s
Motion to Extend Time Within Which to File Appellate Brief was e-mailed to the
Appellate Division of the Harris County District Attorney’s Office on this 6th day of
July, 2015.
/s/ Daucie Schindler__________
DAUCIE SCHINDLER