Arkadi Minassian v. State ( 2015 )

ACCEPTED
01-14-00966-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/31/2015 10:32:08 AM
CHRISTOPHER PRINE
CLERK
01-14-00966-CR
In the
Court of Appeals FILED IN
For the 1st COURT OF APPEALS
HOUSTON, TEXAS
First District of Texas 8/31/2015 10:32:08 AM
At Houston CHRISTOPHER A. PRINE
 Clerk
No. 1300894
In the 338th District Court of
Harris County, Texas

ARKANDI MINNASSIAN
Appellant
v.
THE STATE OF TEXAS
Appellee

STATE’S MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE 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
extension of time in which to file the State’s brief in these cases, and, in support
thereof, presents the following:
1. In the 338th district court of Harris County, Texas, cause 1300894, the State
of Texas v. Arkadi Minassian, appellant, was convicted of fraudulent use or
possession of identifying information.
2. He was assessed punishment of confinement for 30 years in the Institutional
Division of the Texas Department of Criminal Justice.
3. The State’s brief was due on August 28, 2015.
4. An extension of time in which to file the State’s brief is requested until
September 28, 2015.
5. Two previous extension has been requested by the State.
6. The facts relied upon to explain the need for this extension are:
Since my last motion for extension, I have filed motions in cause
number 01-14-0444-CR and 14-14-00831-CR. I will be filing a brief in cause
numbers 01-14-01032-CR and 01-14-01033-CR this week. Also, I prepared for
and participated in a contempt hearing on August 28, 2015, against Sondra
Humphrey, the former official court reporter for County Court at Law No. 8
of Harris County, Texas. Additionally, I answer trial court questions from other
prosecutors on a daily basis. This motion is not sought for delay, but so that
justice may be done.
WHEREFORE, the State prays that this Court will grant an extension of time
until September 28, 2015 in which to file the State’s brief in this case.
Respectfully submitted,
/s/ Abbie Miles
Abbie Miles
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 24072240
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been mailed to the
appellant’s attorney at the following address on August 31, 2015:
Douglas Durham
2800 Post Oak Boulevard, Suite 4100
Houston, TX 77056
/s/ Abbie Miles
Abbie Miles
Assistant District Attorney
Harris County, Texas
Date: August 31, 2015