Blake Alan Cotton v. State ( 2015 )

ACCEPTED
01-14-00444-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/29/2015 3:51:30 PM
CHRISTOPHER PRINE
CLERK
01-14-00444-CR
In the
Court of Appeals FILED IN
For the 1st COURT OF APPEALS
HOUSTON, TEXAS
First District of Texas 6/29/2015 3:51:30 PM
At Houston CHRISTOPHER A. PRINE
 Clerk
No. 1411387
In the 248th District Court of
Harris County, Texas

BLAKE ALAN COTTON
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 248th district court of Harris County, Texas, cause 1421756, the State of
Texas v. Blake Alan Cotton, appellant, was convicted of burglary of a building.
2. He was assessed punishment of confinement for 6 months in a state jail
facility.
3. The State’s brief is due on June 29, 2015.
4. An extension of time in which to file the State’s brief is requested until July
29, 2015.
5. No previous extension has been requested by the State.
6. The facts relied upon to explain the need for this extension are:
Since appellant filed his brief, I have filed briefs in cause numbers 14-13-
00370-CR, 01-14-00861-CR, 14-14-00696-CR, 01-14-00857-CR, and 01-14-
00834-CR. Additionally, in the last month, I prepared for and participated in an
abatement hearing in cause 14-13-00767-CR, and a motion to quash the
indictment in cause number 1465805. Additionally, I answer trial court
questions from other prosecutors on a daily basis. 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 July 29, 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 June 29, 2015:
Emily Detoto
917 Franklin, 4th Floor
Houston, TX 77002
/s/ Abbie Miles
Abbie Miles
Assistant District Attorney
Harris County, Texas
Date: June 29, 2015