Rodrick Odell Williams v. State ( 2015 )

ACCEPTED 01-15-00493-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 11/24/2015 8:49:31 PM CHRISTOPHER PRINE CLERK CAUSE NO. 01-15-00493-CR ____________________ FILED IN IN THE COURT OF APPEALS 1st COURT OF APPEALS HOUSTON, TEXAS FOR THE FIRST SUPREME JUDICIAL DISTRICT 11/24/2015 8:49:31 PM CHRISTOPHER A. PRINE AT HOUSTON Clerk ____________________ RODERICK ODELL WILLIAMS, Appellant, Vs. THE STATE OF TEXAS, Appellee ____________________ Appealed from the 180TH District Court Of Harris County, Texas Cause Number 1373609 ____________________ MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF ____________________ DENA FISHER SBOT: 24034440 440 LOUISIANA, STE 200 HOUSTON, TX 77002 P: 713.222.2201 F: 713.224.2815 d2f@sbcglobal.net TO THE HONORABLE FOURTEENTH COURT OF APPEALS: Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellant, RODRICK ODELL WILLIAMS, files this Motion to Extend Time to File Appellant’s Brief. Appellant’s opening brief is currently due on NOVEMBER 19, 2015. Counsel for Appellant requests a 5-day extension of time to file its brief, making the brief due on November 24, 2015. This is the third request for extension of time to file the opening brief. Counsel for Appellant relies on the following reasons, in addition to the routine matters that counsel must attend to in daily practice, to explain the need for the requested extension: 1. State of Texas v. Jorge Guerrero – Cause No. 201200330J – Aggravated Robbery Certification Hearing – November 2, 2015 2. State of Texas v. Dennis Kendrick – Cause No. 201502740J – Murder Certification Hearing – October 13, 2015 3. State of Texas v. Sergio Ramirez – Cause No. 201505875J – Murder Certification Hearing – October 23, 29, & 30th, 2015. Counsel for Appellant seeks this extension of time to be able to prepare a cogent and succinct brief to aid this Court in its analysis of the issues presented. This request is not sought for delay but so that justice may be done. All facts recited in this motion are within the personal knowledge of the counsel signing this motion, therefore no verification is necessary under Rule of Appellate Procedure 10.2. PRAYER FOR RELIEF For the reasons set forth above, Appellant requests that this Court grant this Motion to Extend Time to File Appellant’s Brief and extend the Deadline for Filing the Appellant’s Brief. Appellant prays for all other relief to which it may be entitled. Respectfully submitted, /s/ Dena Fisher DENA FISHER SBOT: 24034440 440 LOUISIANA, STE 200 HOUSTON, TX 77002 P: 713.222.2201 F: 713.224.2815 d2f@sbcglobal.net Counsel for Appellant CERTIFICATE OF SERVICE I certify that on November 24, 2015, a true and correct copy of the forgoing motion was delivered to the Harris County District Attorney’s Office by efile. /s/ Dena Fisher DENA FISHER SBOT: 24034440 Counsel for Appellant