Dionysios Spiro Kosmetatos v. State ( 2015 )

ACCEPTED
01-15-00095-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/28/2015 12:01:06 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00095-CR
01-15-00094-CR
FILED IN
IN THE COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
FOR THE FIRST DISTRICT OF TEXAS 7/28/2015 12:01:06 PM
CHRISTOPHER A. PRINE
Clerk
DIONYSIOS SPIRO KOSMETATOS
Appellant
v.
THE STATE OF TEXAS
Appellee
On Appeal from Cause Number 1449194 & 1414418
From the 338th District Court of Harris County, Texas
APPELLANT’S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE AN
APPELLATE BRIEF
To the Honorable Court of Appeals of Texas:
Comes now Appellant, in accordance with Rules 10.5(b)(1) and 38.6(d) of the
Texas Rules of Appellate Procedure, and files this motion for extension of time in
which to file the Appellant’s brief in this cause, and, in support thereof, presents the
following:
1. In the 338th District Court of Harris County, Texas, following a jury trial,
Appellant was sentenced on January 15, 2015 in Cause No. 1449194 &
1414418 The State of Texas v. Dionysios Spiro Kosmetatos.
2. For two counts of Aggravated Assault – Public Servant, Appellant was
sentenced to forty years in the Texas Department of Corrections.
3. A written notice of appeal was timely filed on January 16, 2015.
4. The Appellant’s brief was due June 22, 2015.
5. An extension of time in which to file the Appellant’s brief is requested until
October 22, 2015.
6. Two previous extensions have been granted to the Appellant.
7. The facts relied upon to explain the need for this extension are:
a. Appellant’s counsel gave birth to a baby earlier than expected and is
out on maternity leave.
Consequently, additional time will be necessary in which to file Appellant’s
brief in this case. The Appellant’s motion is not for purposes of delay, but so that
justice may be done.
WHEREFORE, the Appellant prays that this Court will grant an additional
extension of time until October 22, 2015 in which to file Appellant’s brief in this
cause.
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Respectfully submitted,
LAW OFFICE OF TONYA ROLLAND
/s/ Tonya Rolland McLaughlin____
Tonya Rolland McLaughlin
4301 Yoakum Boulevard
Houston Texas 77006
Phone: (713) 529-8500
Fax: (713) 453-2203
TBN 24054176
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been delivered via
email to the following:
Alan Curry
Chief Prosecutor, Appellate Division
Harris County District Attorney’s Office
1201 Franklin Suite 600
Houston, Texas 77002-1923
_/s/ Tonya Rolland McLaughlin__
Tonya Rolland McLaughlin
Attorney for Appellant
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