Abner L. Washington ( 2015 )

ACCEPTED
01-14-00885-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/10/2015 1:33:10 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00885-CR
In the FILED IN
Court of Appeals 1st COURT OF APPEALS
HOUSTON, TEXAS
For the 6/10/2015 1:33:10 PM
First Judicial District of Texas CHRISTOPHER A. PRINE
At Houston Clerk
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No. 1430059
In the 248th District Court of
Harris County, Texas
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ABNER L. WASHINGTON
Appellant
v.
THE STATE OF TEXAS
Appellee
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STATE’S MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE APPELLATE BRIEF
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TO THE HONORABLE COURT OF APPEALS OF TEXAS:
COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.1(a)
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 this case, and, in support thereof,
presents the following:
1. In the 248th District Court of Harris County, Texas, in The State of Texas v.
Abner L. Washington, Cause Number 1430059, appellant was convicted of
possession of a controlled substance.
2. Appellant was sentenced to sixty days incarceration in the Harris County Jail.
3. The State’s brief was due on June 10, 2015.
5. An extension of time in which to file the State’s brief is requested until July 10,
2015.
6. One previous extension has been requested by the State.
7. The facts relied upon to explain the need for this extension are:
a) The undersigned attorney was assigned this case on March 22, 2014;
b) Since the undersigned attorney was assigned this case, the attorney finished
writing the State’s briefs in the following cases:
(1) Cause Number 01-14-00900-CR, Felicity Burris, Appellant v. The State of
Texas, Appellee, which involved one point of error and two volumes of
the reporter’s record and is due on May 13, 2015; and
(2) Cause Number 01-14-00748-CR, James Lee Skinner, Appellant v. The State
of Texas, Appellee, which involved three points of error and is due on May
18, 2015.
c) The undersigned attorney has also been assigned to engaged in the
preparation of the State’s Brief in the following appellate cause numbers
(1) Cause Number 01-14-00772-CR, Thanh Hoang, Appellant v. The State of
Texas, Appellee, which involves one point of error; and
(2) 14-14-00874-CR, Charles Roberts, Appellant v. The State of Texas, Appellee,
which involves three points of error.
d) Additionally, the undersigned attorney has also been out of the office last
week from the flooding in Houston and from attending the Conference on
Criminal Appeals in Austin.
WHEREFORE, the State prays that this Court will grant an extension of time until
July 10, 2015 in which to file the State’s brief in this case.
Respectfully submitted,
/s/
Carly Dessauer
________________________________________________________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served to
appellant’s attorney on June 10, 2015 through TexFile:
Sarah V. Wood
Assistant Public Defender, Harris County
1201 Franklin Street, 13th Floor
Houston, Texas 77002
sarah.wood@pdo.hctx.net
/s/ Carly Dessauer
________________________________________________________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
curry_alan@dao.hctx.net
Date: June 10, 2015