Cary, Stacy Stine ( 2015 )

PD-1341-1 COURT OF CRIMINAL APPEAL AUSTIN, TEXA Transmitted 8/11/2015 5:45:39 PI Accepted 8/12/2015 10:07:55 Al IN THE ABELAc?er COURT OF COURT OF CRIMINAL APPEALS OF TEXAS No. PD-1341-14 filed IN COURT OF CRIMINAL APPEALS August 12, 2015 STACY STINE CARY, Appellant abelacosta, clerk THE STATE OF TEXAS, Appellee XPC On Appeal from the Court of Appeals, Fifth District of Texas at Dallas Court of Appeals No. 05-12-01421-CR APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE REPLY BRIEF BY TWO BUSINESS DAYS Appellant Stacy Stine Cary respectfully moves for an extension of time to file her Appellant's Brief by two business days, until August 18, 2015. In support of this motion, she would respectfully show as follows: 1. The deadline for filing the Appellant's Brief is Friday, August 14, 2015. 2. Appellant seeks an extension of time of two business days, until Tuesday, August 18, 2015. 3. An extension is necessary because of appellate counsel's schedule and the complexity of the issues. Appellant's counsel has an evidentiary hearing in a Unopposed Motion for Extension of Time—Page 1 criminal case on Thursday, August 13, 2015 and an all-day deposition in a civil case on Friday, August 14, 2015, that cannot be moved. Appellee also has a likely pretrial conference for a criminal trial in Hunt County, Texas on Monday, August 17, 2015, for a likely trial on August 24, 2015, for which he is preparing. APPELLEE, THE STATE OF TEXAS, DOES NOT OPPOSE THIS REQUESTED EXTENSION. 4. The Court has previously extended the time for this reply brief by 18 days. If granted, Ms. Cary will not request a further extension. Respectfully submitted, /s/ John M. Helms John M. Helms Texas Bar No. 09401001 BRODEN, MICKELSEN, HELMS & SNIPES, LLP 2600 State Street Dallas, Tx 75204 Tel: (469)951-8496 Fax:(214)720-9594 john@j ohnhelmslaw.com ATTORNEY FOR APPELLANT, STACY STINE CARY CERTIFICATE OF CONFERENCE Undersigned counsel has conferred with Joseph Corcoran, counsel for Appellee, the State of Texas, and the Appellee does not oppose this motion. Unopposed Motion for Extension of Time—Page 2 /s/ John M. Helms John M. Helms CERTIFICATE OF SERVICE This certifies that a true and correct copy of this instrument has been served on counsel of record on August 11, 2015, as follows: Joseph Corcoran Assistant Attorney General P.O. Box 12548 Capitol Station Austin, TX 78711 * DELIVERED VIA E-MAIL * /s/ John M. Helms John M. Helms Unopposed Motion for Extension of Time—Page 3