Andre Demont Thompson v. State ( 2015 )

ACCEPTED
01-14-00862-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/13/2015 3:56:09 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00862-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
for the 7/13/2015 3:56:09 PM
First District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston

No. 1364692
In the 178th District Court
Of Harris County, Texas

ANDRE DEMONT THOMPSON
Appellant
v.
THE STATE OF TEXAS
Appellee

STATE’S MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE AN APPELLATE BRIEF

TO THE HONORABLE COURT OF APPEALS OF TEXAS:
COMES NOW THE STATE OF TEXAS, in accordance with Rules
10.5(b)(1) and 38.6(d) of the Texas Rules of Appellate Procedure, and files this
motion for an extension of time in which to file the State’s Brief in this cause, and,
in support thereof, presents the following:
1. On October 8, 2014, appellant was convicted by a jury of murder and
sentenced to 30 years in the Institutional Division of the Texas Department
of Criminal Justice.
2. Appellant filed a timely written notice of appeal.
3. The State’s Brief is due on July 22, 2015.
4. An extension of time in which to file the State’s Brief is requested until
August 21, 2015. No previous extensions have been granted.
5. The following facts are relied upon to show good cause for the requested
extension:
i. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. AP-77,039, Jeffery Keith
Prevost, Appellant v. The State of Texas, Appellee, which was
filed on June 30, 2015.
ii. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. 14-14-00956-CR, Jessie
Coleman, Appellant v. The State of Texas, Appellee, which was
filed on July 6, 2015.
iii. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. 01-14-01035-CR, Julia
Juarez, Appellant v. The State of Texas, Appellee, which was
filed on July 13, 2015.
iv. The undersigned attorney will be on vacation from July 14,
2015 through July 22, 2015.
WHEREFORE, the State prays that this Court will grant an additional
extension of time until August 21, 2015 in which to file the State’s Brief in this
cause.
Respectfully submitted,
/s/ Heather A. Hudson
HEATHER A. HUDSON
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24058991
hudson_heather@dao.hctx.net
curry_alan@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been submitted
for service by e-filing to the following address:
Franklin Bynum
2814 Hamilton Street
Houston, Texas 77002
Tel: (713) 343-8844
fgb@lawfgb.com
/s/ Heather A. Hudson
HEATHER A. HUDSON
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24058991
Date: July 13, 2015