Shaun Deville Briggs v. State ( 2015 )

ACCEPTED
01-15-00269-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
5/18/2015 3:34:46 PM
CHRISTOPHER PRINE
CLERK
IN THE
FIRST COURT OF APPEALS
OF TEXAS
FILED IN
1st COURT OF APPEALS
SHAUN DEVELLE BRIGGS § HOUSTON, TEXAS
§ 5/18/2015 3:34:46 PM
VS. § Case Number No. 01-15-00269-CR
CHRISTOPHER A. PRINE
§ Clerk
THE STATE OF TEXAS §
First Motion to Extend Time to File Brief
Now comes Shaun Develle Briggs, appellant in the above-styled and numbered
cause, by and through assistant public defender, Jani J. Maselli Wood, and
respectfully moves the Court for an extension of time within which to file the
appellate brief, and for cause would show the Court as follows:
I.
On February 18, 2015, Mr. Briggs was convicted of the offense of aggravated
robbery and was sentenced to 15 years imprisonment in the Texas Department of
Criminal Justice - Institutional Division. He was convicted in cause
number1430016 in the 263rd District Court of Harris County, Texas, styled The
State of Texas v. Shaun Develle Briggs.
II.
The brief is currently due May 14, 2015. No extensions have been requested.
III.
Undersigned counsel is requesting 30 days from that due date until June 14,
2015.
IV.
Counsel has been working on a murder appeal in State v. Joe Lee Bowden. The
record is lengthy;
On April 30, 2015, counsel filed a PDR in State v. Joshua London;
On March 25, 2015, the Court of Criminal Appeals granted the State’s PDR
in Osmin Peraza v. State, NOS. PD-0100 & PD-0101-15. The CCA ordered expedited
briefing (15 days per side with no extensions of time permitted). Undersigned
counsel filed the brief on April 23, 2015. The CCA then set argument for May 20,
2015. This is also requiring additional time to prepare for argument.
Additionally, in January 2015, counsel made plans to attend a wedding and
graduation in Massachusetts from May 14-17, 2015. The tickets are nonrefundable.
V.
This request is made not to delay the proceedings, but to ensure that Mr. Briggs
is adequately represented.
WHEREFORE, PREMISES CONSIDERED, Mr. Briggs respectfully prays
that this undersigned counsel be designated as the attorney of record in this cause
and that the Court permit an extension of time until June 14, 2015.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Jani Maselli Wood
_______________________
JANI J. MASELLI WOOD
Assistant Public Defender
State Bar Number 00791195
Harris County Texas
1201 Franklin, 13th Floor
Houston Texas 77002
(713) 368-0001
(713) 368-9278 (Fax)
Jani.Maselli@pdo.hctx.net
Attorney for Appellant,
Shaun Develle Briggs
CERTIFICATE OF SERVICE
Pursuant to Tex. R. App. Proc. 9.5, this certifies that on May 18, 2015, a
copy of the foregoing was emailed to counsel for the state (through texfile.com) at
the following address:
Alan Curry
Assistant District Attorney
1201 Franklin Street, 6th Floor
Houston, TX 77002
curry_alan@dao.hctx.net
/s/ Jani J Maselli Wood
___________________________________
JANI J. MASELLI WOOD