Michael Anthony Davila v. State ( 2015 )

ACCEPTED 01-15-00560-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 9/18/2015 2:59:08 PM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS FOR THE FIRST DISTRICT COURT OF APPEALS HOUSTON, TEXAS FILED IN NO. 01-15-00560-CR 1st COURT OF APPEALS HOUSTON, TEXAS MICHAEL ANTHONY DAVILA 9/18/2015 2:59:08 PM APPELLANT On Appeal from Cause Number 1359876 CHRISTOPHER A. PRINE From the 351 District Court Clerk st Harris County, Texas V. THE STATE OF TEXAS APPELLEE APPELLANT’S MOTION FOR EXTENSION TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS: COMES NOW, Michael Anthony Davila, and files this Motion to Extend Time to File Brief, and in support thereof, would respectfully show the Court the following: I. The current deadline for filing Appellant’s Brief is September 16, 2015. There have not been any previous motions for extension of time to file Appellant’s Brief. II. Counsel has been engaged in work in the Harris County Public Defender’s Office on many cases, including the following:  Lenin Lopez, 01-13-01079-CR, reversed and set for rehearing in cause #1403196  Felix Irizarry, 14-14-00827-CR  Darryle Robertson, 14-15-00132-CR  Ruben Totten, PD-0483-15  Trey Foster, 14-15-00497-CR  Pete Rodriguez, 14-15-00339-CR  Craig Beal, 01-12-00896-CR  Kori Henegar, 14-15-00529-CR  Counsel has been researching and writing for several trial cases assigned to the Public Defender’s Office Trial Division. III. Appellant’s attorney requests this extension which is necessary so that the brief can be thoroughly written and timely filed. This motion is not made for the purpose of delay. PRAYER WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court grants this extension to October 18, 2015. Respectfully Submitted, ALEXANDER BUNIN Chief Public Defender Harris County, Texas /s/ Sarah V. Wood SARAH V. WOOD Assistant Public Defender Harris County, Texas Texas Bar Number 24048898 1201 Franklin, 13th Floor Houston, Texas 77002 Phone: (713) 368-0016 Fax: (713) 368-9278 Sarah.Wood@pdo.hctx.net CERTIFICATE OF SERVICE By my signature below, I hereby certify that a true and correct copy of the above and foregoing has been served upon the Harris County District Attorney's Office – Alan Curry, via the electronic filing service. /s/ Sarah V. Wood Sarah V. Wood