Erick Eduardo Hernandez v. State ( 2015 )

ACCEPTED 14-15-00209-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 6/22/2015 12:45:57 PM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS FOR THE FOURTEENTH DISTRICT OF TEXAS NO. 14-15-00209-CR FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS ERICK EDUARDO HERNANDEZ 6/22/2015 12:45:57 PM Appellant, CHRISTOPHER A. PRINE On Appeal 184th From theClerk District Court of Harris County, Texas V. Trial Cause No. 1392161 THE STATE OF TEXAS Appellee SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE JUDGES OF SAID COURT: ANGELA CAMERON, attorney of record for Appellant in the above cause, would respectfully request the Court to grant her motion to extend time for file brief. In support of said motion, counsel would show unto the Court the following: I. This appeal lies from Appellant's conviction in The State of Texas v. Erick Hernandez Cause Number 1392161 in the 184th District Court of Harris County. Hernandez was found guilty of murder and sentenced to life imprisonment in the Texas Department of Corrections. Notice of Appeal was timely filed. The brief is due on June 22, 2015. One prior extension has been granted. II. Counsel will not be able to file the brief for the following reasons: 1. Counsel was out of the office the week of May 25th through June 1, 2015 due to Memorial Day, Flooding in Downtown and attending the Conference on Criminal Appeals CLE in Austin. 2. Counsel has been helping in the trial preparation in State of Texas v. Gaylin Lavan, Cause Number 1440861 in the 183rd District Court of Harris County. The case was set for trial on June 8, 2015. 3. Counsel has been helping in the trial preparation in State of Texas v. Rusty Terry, Cause Number 1451197 in the 183rd District Court of Harris County. The case was set for trial on June 8, 2015. 4. Counsel has been helping in the trial preparation in State of Texas v. Tonia Haskett, Cause Number 1439465 in the 180th District Court of Harris County. The case was set for trial on June 15, 2015. 5. Counsel has been helping in the trial preparation in State of Texas v. Derek Boone, Cause Number 1416801 in the 228th District Court of Harris County. The case was set for trial on June 22, 2015. 6. Counsel was preparing for oral argument in State of Texas v. Issac Smith, Cause Number 14-14-00139-CR which was held on June 17, 2015. 7. Counsel has been investigating a possible Motion for New Trial in State of Texas v. Willie Clarke, Cause Numbers 1453864, 1457279 and 1465671 in the 178th District Court of Harris County. The deadline for filing a Motion for New Trial is June 27, 2014. VI. 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 for at least thirty (30) days. Respectfully submitted, Alexander Bunin Chief Public Defender /s/ Angela Cameron Angela Cameron State Bar No. 00788672 Harris County Public Defender’s Office 1201 Franklin 13th Floor Houston, Texas 77002 Tel: 713-368-0016 angela.cameron@pdo.hctx.net CERTIFICATE OF SERVICE I certify that on the 22nd day of June 2015 a copy of the foregoing instrument has been electronically served upon the State of Texas. /s/ Angela Cameron ANGELA CAMERON