Benjamin Maurine Sadler v. State ( 2014 )

ACCEPTED
01-14-00422-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/31/2014 2:04:32 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00422-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
for the 12/31/2014 2:04:32 PM
First District of Texas CHRISTOPHER A. PRINE
Clerk
At Houston

No. 1382570
In the 183rd District Court
Of Harris County, Texas

BENJAMIN MAURINE SADLER
Appellant
v.
THE STATE OF TEXAS
Appellee

STATE’S SECOND MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE AN 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 an extension of time in which to file the State’s brief in this cause, and,
in support thereof, presents the following:
1. On May 6, 2014, a jury convicted appellant of possession of a controlled
substance with intent to deliver and sentenced him to 25 years in the
Institutional Division of the Texas Department of Criminal Justice.
2. Appellant filed a timely written notice of appeal on May 6, 2014.
3. The State’s brief was due on December 31, 2014.
4. An extension of time in which to file the State’s brief is requested until
January 30, 2015.
5. The following facts are relied upon to show good cause for the requested
extension:
i. The undersigned attorney has been engaged in preparation for
oral argument before the Fourteenth Court of Appeals on
December 10, 2014 in Cause No. 14-13-00839-CR, Patrick
Marcel Brown, Appellant v. The State of Texas, Appellee.
ii. The undersigned attorney has been engaged in the preparation
of the State’s Post-submission Brief in Cause No. 01-12-01124-
CR, Casey Demon Carmon, Appellant v. The State of Texas,
Appellee.
iii. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. 14-14-00389-CR, Eric Lopez,
Appellant v. The State of Texas, Appellee.
iv. The undersigned attorney has been engaged in the preparation
of the State’s Brief in Cause No. 14-14-00139-CR, Isaac Smith,
Appellant v. The State of Texas, Appellee.
v. The undersigned attorney was on Christmas vacation from
December 22nd through December 26th.
WHEREFORE, the State prays that this Court will grant an additional
extension of time until January 30, 2015 in which to file the State’s brief in this
cause.
Respectfully submitted,
/s/ Heather A. Hudson
HEATHER A. HUDSON
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24058991
hudson_heather@dao.hctx.net
curry_alan@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been submitted
for service by e-filing to the following address:
Kelly Ann Smith
P.O. Box 10751
Houston, Texas 77206
Tel: (281) 734-0668
Kelly.A.Smith.06@gmail.com
/s/ Heather A. Hudson
HEATHER A. HUDSON
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24058991
Date: December 31, 2014