Keith Dwayne Jones v. State ( 2014 )

ACCEPTED
14-14-00733-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
12/31/2014 10:53:20 AM
CHRISTOPHER PRINE
CLERK
No. 14-14-00733-CR
No. 14-14-00734-CR
FILED IN
In the 14th COURT OF APPEALS
HOUSTON, TEXAS
Court of Appeals
12/31/2014 10:53:20 AM
For the
CHRISTOPHER A. PRINE
Fourteenth District of Texas Clerk
At Houston

No. 1325864
No. 1329499
In the 228th District Court
Harris County, Texas

KEITH DWAYNE JONES
Appellant
v.
THE STATE OF TEXAS
Appellee

STATE’S SECOND 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 this case, and, in support thereof, presents the
following:
1. In the 228th District Court of Harris County, Texas, in cause numbers 1325864
and 1329499, the Appellant was convicted on August 27, 2014, in The State of Texas v.
Keith Dwayne Jones.
2. For two offenses of aggravated robbery, the Appellant’s punishment was assessed
at 25 years in prison.
3. Written notices of appeal were timely filed on September 23, 2014.
4. The Appellant’s brief was filed with this Court on October 27, 2014.
5. The State’s brief was due to be filed with this Court on December 22, 2014.
6. An extension of time in which to file the State’s brief is requested until December
31, 2014.
7. One previous extension has been granted to the State.
8. The facts relied upon to explain the need for this extension are:
With his numerous duties as Chief of the Appellate Division, the undersigned
assistant district attorney has needed some additional time in order to respond to
the appellant’s brief in this case.
WHEREFORE, the State prays that this Court will grant an extension of time until
December 31, 2014, in which to file the State’s brief in these cases.
Respectfully submitted,
/s/ Alan Curry
ALAN CURRY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 05263700
curry_alan@dao.hctx.net
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 addresses on December 31, 2014:
Ken Goode
Attorney at Law
P.O. Box 590947
Houston, Texas 77002
/s/ Alan Curry
ALAN CURRY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 05263700
curry_alan@dao.hctx.net
Date: December 31, 2014