Zachary Keith Hill v. State ( 2015 )

ACCEPTED
01-14-00945-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/31/2015 10:45:17 AM
CHRISTOPHER PRINE
CLERK
IN THE COURT OF APPEALS OF TEXAS
FIRST JUDICIAL DISTRICT
FILED IN
ZACHARY HILL § 1st COURT OF APPEALS
HOUSTON, TEXAS
§ 7/31/2015 10:45:17 AM
vs. § Case No. 01-14-00945-CR
CHRISTOPHER A. PRINE
§ Clerk
THE STATE OF TEXAS §
MOTION TO EXTEND TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THIS COURT:
Appellant Zachary Hill, through counsel, moves the Court to extend time to file
his brief, due July 30, 2015, for the following reasons:
1. Counsel, Assistant Public Defender, Melissa Martin has been working on many
cases including, but not limited to Humphrey v. State , 14-15-00226-CR; Carter v. State, 01-
14-01006-CR; Gilder v. State, PD-0975-15; as well as the instant case and has been unable
to complete the brief despite due diligence.
2. This is the first request for an extension in this case.
In view of the foregoing, Mr. Hill asks the Court to extend the time to file his
brief for 30 days, or up to and including August 29, 2015. This request is made in the
interest of justice and effective assistance of counsel and not for purposes of delay.
Respectfully submitted,
ALEXANDER BUNIN
Chief, Harris County Public Defender’s Office
/s/ Melissa Martin
_________________________________
MELISSA MARTIN
Assistant Public Defender
TX. Bar No. 24002532
1201 Franklin St., 13th Fl.
Houston, TX 77002
email: melissa.martin@pdo.hctx.net
713/274-6709 Fax 713/437-4319
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing motion was electronically served on the
Harris County District Attorney’s office on July 31, 2015.
/s/ Melissa Martin
_________________________________
Melissa Martin