Ana Maria Gonzalez-Angulo v. State ( 2015 )

ACCEPTED 01-14-00886-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 5/15/2015 2:34:23 PM CHRISTOPHER PRINE CLERK No. 01 -14-00886-CR In the FILED IN Court of Appeals for the First District of Texas1st COURT OF APPEALS HOUSTON, TEXAS At Houston 5/15/2015 2:34:23 PM CHRISTOPHER A. PRINE Clerk In the 248 1h District Court Of Harris County, Texas ANA MARIA GONZALEZ-ANGULO Appellant V. THE STATE OF TEXAS Appellee MOTION FOR EXTENSION OF TIME TO FILE BRIEF Pursuant to Rule 38.6(d) and Rule 10.5(b) of the Texas Rules of Appellate Procedure, Appellant respectfully requests this Court to grant this motion for extension of time to file Appellant's brief, and offers the following facts in support of this request: 1. Sentence was imposed on September 29, 2014, and motion for new trial was filed on October 29, 2014. Notice of appeal was timely filed. 2. The reporter' s record was filed on April 16, 2015, and appellant's brief is due on Monday, May 18, 2015. 3. No previous extensions of time have been requested in this case. 4. The case at bar is an aggravated assault. The issues are complicated and the trial took place over two weeks. In addition, a portion of the appellate record is under seal and appellate counsel needs time to consider pursuing a modification to that order. 5. Appellant asks this court for an extension of time until Wednesday, June 17, 2015, to file her brief in this case. Appellant respectfully prays this Honorable Court grant this motion for extension of time to file an appellate brief. Respectfully submitted, /s/ Barbara Drumheller Barbara A. Drumheller 650 West Bough Ln, Ste 150-130 Houston, Texas 77024 713-504-4492 barbaradrumheller@gmail.com Texas Bar No. 00793643 2 CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrnment has been served on the District Attorney's Office through the court system's electronic file manager. /s/ Barbara Drumheller Barbara Dmmheller 650 West Bough Ln., Ste 150-130 Houston, Texas 77024 713-504-4492 barbaradrumheller@gmaiI.com Texas Bar No. 00793643 3