Roy Vasquez v. State ( 2015 )

ACCEPTED 01-15-00183-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 7/31/2015 11:32:49 AM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS FOR THE FIRST COURT OF APPEALS DISTRICT No. 01-15-00183-CR FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS ROY VASQUEZ 7/31/2015 11:32:49 AM Appellant, CHRISTOPHER A. PRINE Clerk On Appeal From the 230th V. District Court of Harris County Trial Cause Number 1437421 THE STATE OF TEXAS Appellee APPELLANT'S FINAL MOTION TO EXTEND TIME TO FILE BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Roy Vasquez, Appellant in the above cause, would respectfully request that the Court grant his motion to extend the time to file his brief. In support of said motion, Appellant would show unto the Court the following: I. This appeal lies from the Appellant's conviction in The State of Texas v. Roy Vasquez, cause number 1437421 in the 230th District Court of Harris County, Texas. The Appellant was charged by indictment with aggravated sexual assault on August 8, 2014. The Appellant was found guilty of the lesser-included offense of sexual assault on February 12, 2015, following a jury trial. The Appellant was sentenced to seventeen (17) years confinement in the Texas Department of Corrections – Institutional Division. Two previous extensions have been requested and granted. The Appellant’s completed brief is being filed simultaneously with this motion. II. Appellant's attorney of record has not been able to timely file the brief for the following reasons: 1. A direct appeal brief in Jeremy Washington v. State of Texas, cause number 1862655, which was submitted on July 13, 2015; 2. A direct appeal brief in Kenneth Brown v. State of Texas, cause number 1389982, which is due on August 5, 2015; 3. A direct appeal brief in Sylvia Collins v. State of Texas, cause number 1390220, which is due on August 17, 2015; 4. Investigation for a potential Motion for New Trial in Alton Jolivette v. State of Texas, cause numbers 1428512, 1428510 & 1428708, which would be due on August 24, 2015. III. An extension of time is necessary so that the brief can be timely filed. This motion is not made for the purpose of delay. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court will grant this requested extension of time to file the Appellant's Brief in the above cause and extend the time for filing the brief to today, July 31, 2015. Respectfully submitted, Alexander Bunin Chief Public Defender /s Mark Kratovil______________ Mark Kratovil State Bar No. 24076098 Harris County Public Defender’s Office Assistant Public Defender 1201 Franklin, 13th Floor Houston, Texas 77002 Tel: (713)274-6728 e-Fax: (713)437-4339 CERTIFICATE OF SERVICE I certify that on July 31, 2015, a copy of the foregoing instrument has been served upon the State of Texas by electronic delivery to the Appellate Division of the Harris County District Attorney’s Office. /s Mark Kratovil MARK KRATOVIL