Richard Contreras, Sr. v. State ( 2015 )

ACCEPTED
01-14-00758-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/12/2015 11:53:05 AM
CHRISTOPHER PRINE
CLERK
No. 01-14-00758-CR
In the
Court of Appeals FILED IN
1st COURT OF APPEALS
For the HOUSTON, TEXAS
First District of Texas 6/12/2015 11:53:05 AM
At Houston CHRISTOPHER A. PRINE
 Clerk
No. 1401233
In the 230th District Court
Of Harris County, Texas

RICHARD CONTRERAS
Appellant
V.
THE STATE OF TEXAS
Appellee

STATE’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE COURT OF APPEALS:
THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 2 & 10.5, moves for
an extension of time in which to file its appellate brief and in its motion, would
show the Court the following:
1. The appellant was charged with the aggravated sexual assault of a child
committed on July 1, 2013 (CR – 15). He pled “guilty” to the charge
(CR – 23-32). The trial court sentenced him to 50 years in prison on June
10, 2014 (CR – 38). The appellant filed a motion for new trial that same
day, which was denied on August 15 (CR – 41-46). The appellant then
filed a notice of appeal on September 4, 2014, and the trial court certified
that he had waived his right to appeal (CR – 34, 57).
2. The State’s brief is due on June 12, 2015. The State hereby requests a
30-day extension for the filing of the State’s brief.
3. The following facts are relied upon to show good cause for an extension
of time to allow the State to file its brief:
a. The record in this case is over 130 megabytes in length split over
ten files and will take some time to process.
b. The undersigned attorney researched and answered by email more
than 50 legal questions of trial prosecutors since the appellant filed
his brief. The undersigned attorney researched and answered even
more such questions by phone during that time period.
c. The undersigned attorney has been involved in completing the
following written appellate project since the appellant filed his
brief:
(1) Johnathan Castaneda v. The State of Texas
No. 01-14-00389-CR
No. 01-14-00390-CR
Brief filed May 18, 2015
(2) Griselda Aza v. The State of Texas
No. 14-14-00241-CR
No. 14-14-00242-CR
Brief to be filed June 26, 2015
WHEREFORE, the State prays that this Court will grant the requested extension.
Respectfully submitted,
/s/ Eric Kugler
ERIC KUGLER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
Kugler_eric@dao.hctx.net
TBC No. 796910
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served by
efile.txcourts.gov to:
Michael Driver
Attorney at Law
402 Main, 4th floor
Houston, TX 77002
Mikedriverlaw@gmail.com
/s/ Eric Kugler
ERIC KUGLER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
TBC No. 796910
Date: June 12, 2015