Jesse Dimas Alvarado v. State ( 2015 )

ACCEPTED
01-14-00857-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
5/13/2015 8:55:27 AM
CHRISTOPHER PRINE
CLERK
No. 01-14-00857-CR
In the
Court of Appeals FILED IN
For the 1st COURT OF APPEALS
HOUSTON, TEXAS
First District of Texas 5/13/2015 8:55:27 AM
At Houston CHRISTOPHER A. PRINE
 Clerk
No. 1410607
In the 185th District Court of
Harris County, Texas

JESSE DIMAS ALVARADO
Appellant
v.
THE STATE OF TEXAS
Appellee

STATE’S 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 these cases, and, in support
thereof, presents the following:
1. In the 185th district court of Harris County, Texas, cause 1410607, the State of
Texas v. Jesse Dimas Alvarado, appellant, was convicted of being a felon in
possession of a weapon.
2. He was assessed punishment of confinement for 5 years in the Institutional
Division of the Texas Department of Criminal Justice.
3. The State’s brief is due on May 13, 2015.
4. An extension of time in which to file the State’s brief is requested until June
15, 2015.
5. One previous extension has been requested by the State.
6. The facts relied upon to explain the need for this extension are:
Since my last motion for extension, I have filed a brief in cause number
01-14-00615-CR, and I will be filing a brief in cause number 14-13-00370-CR
in the next week. I was set for trial on May 4th, 2015 on the State of Texas v.
Sidney Darrell in cause number 1421932. The case did not go to trial on May 4th,
but was carried day to day for the entire week. The trial was going to
commence on May 8th, but the defendant pled. Much of my time throughout
the last month has been dedicated to trial preparation in this case. This motion
is not sought for delay, but so that justice may be done.
WHEREFORE, the State prays that this Court will grant an extension of time
until June 15, 2015 in which to file the State’s brief in this case.
Respectfully submitted,
/s/ Abbie Miles
Abbie Miles
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 24072240
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 address on May 13, 2015:
Timothy A. Hootman
2402 Pease Street
Houston, TX 77003
Thootman2000@yahoo.com
/s/ Abbie Miles
Abbie Miles
Assistant District Attorney
Harris County, Texas
Date: May 13, 2015