Michael W. Peters v. State ( 2015 )

ACCEPTED
01-15-00130-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
5/4/2015 5:00:45 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00130-CR
IN THE FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
COURT OF APPEALS FOR THE FIRST SUPREME JUDICIAL DISTRICT
5/4/2015OF TEXAS
5:00:45 PM
CHRISTOPHER A. PRINE
Clerk
AT HOUSTON
....................................................................................................................................
TRIAL COURT NO. 1413407
IN THE 176TH DISTRICT COURT
OF HARRIS COUNTY, TEXAS
....................................................................................................................................
MICHAEL W. PETERS, APPELLANT
V.
THE STATE OF TEXAS, APPELLEE
...................................................................................................................................
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF
....................................................................................................................................
Charles Hinton
P.O. Box 53719
Houston, Texas 77052-3719
832-603-1330
chashinton@sbcglobal.net
SBOT #09709800
Attorney for Appellant
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS
FOR THE FIRST SUPREME JUDICIAL DISTRICT:
Comes now appellant, Michael W. Peters, pursuant to TEX. R. APP. PROC.
10.5(b) and 38.6, and moves the Court for an extension of time to file appellant's
brief, and in support shows the following:
(A) the deadline for filing appellant's brief is May 11, 2015.
(B) the length of the extension sought is until June 10, 2015.
(C) the facts relied upon to reasonably explain the need for an extension
are:
Appellant's attorney has been preparing for and completed a jury trial in
the 209th District Court in
1. The State of Texas vs. Curtis Babers, cause number 1299015 (sexual
assault) which began with a motion hearing and jury selection on April 21, 2015
and lasted through the afternoon hours of April 23, 2015 at which time the jury
returned a verdict on punishment and defendant Babers was sentenced.
Appellant's attorney has also been preparing for jury trial in the following
cases in the 209th District Court:
1. The State of Texas vs. Byron Garrick, cause number 1354246 (Indecency
with a Child) set for jury trial the week of May 11, 2015.
2. The State of Texas vs. Jacoy O'Hara, cause number 1418602 (aggravated
robbery) set for jury trial the week of May 18, 2015.
3. The State of Texas vs. John Davis, cause number 1364895 (Aggravated
Sexual Assault of a Child) & cause number 1397631 (Sexual Assault of a Child) set
for jury trial the week of June 8, 2015.
(D) One previous extension has been granted.
Wherefore, undersigned counsel prays this honorable Court to extend the
time for filing appellant's brief until June 10, 2015.
Respectfully submitted,
/s/Charles Hinton
Charles Hinton
P.O. Box 53719
Houston, Texas 77052-3719
832-603-1330
chashinton@sbcglobal.net
SBOT #09709800
Attorney for Appellant
CERTIFICATE OF COMPLIANCE
Appellant certifies that the word count of this document is 430.
/s/Charles Hinton
Charles Hinton
CERTIFICATE OF SERVICE
I certify that a copy of this motion has been electronically served upon Alan
Curry, Chief Prosecutor, Appellate Division, Harris County District Attorney's
Office, 1201 Franklin St., Ste. 600, Houston, Texas 77002 on May 4, 2015.
/s/Charles Hinton
Charles Hinton