Cody Crymes v. State ( 2015 )

ACCEPTED
01-15-00206-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/17/2015 1:04:29 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00206-CR
FILED IN
1st COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
7/17/2015 1:04:29 PM
FIRST JUDICIAL DISTRICT CHRISTOPHER A. PRINE
Clerk
HOUSTON, TEXAS
__________________________________________________________
No. 17166
IN THE 253RD DISTRICT COURT OF
CHAMBERS COUNTY, TEXAS
__________________________________________________________
CODY CRYMES § Appellant
v. §
STATE OF TEXAS § Appellee
__________________________________________________________
STATE'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF
__________________________________________________________
Cheryl Swope Lieck
District Attorney
Chambers County, Texas
Kathy Esquivel
Assistant District Attorney
Chambers County, Texas
P.O. Box 1409
Anahuac, Texas 77514
(409) 267-2682
(409) 267-3105
kesquivel@co.chambers.tx.us
COMES NOW the State of Texas, by and through her Assistant District
Attorney, Kathy Esquivel, and, pursuant to TEX. R. APP. PRO. 73, presents this
Motion for Extension of Time. In support of the motion, the State submits the
following:
1. The above case is on appeal from a plea of guilty in the 253rd Judicial District
Court of Chambers County, Texas.
2. The State’s brief is currently due on July 17, 2015.
3. This is the State’s first Motion for Extension of Time.
4. Counsel for the State was preparing for another jury trial in the 253rd District
Court and did not have adequate time to complete the brief in this case.
Further, counsel for the State was recovering from an illness that required
several days off from work.
5. The State requests that the time for filing the State’s Brief be extended by 14
days to July 31, 2015. The State requests this extension not for delay, but to
see that justice is done.
WHEREFORE, PREMISES CONSIDERED, the State prays that this
Court grant the State’s Motion for Extension of Time and extend the due date of the
State’s Appellate Brief until July 31, 2015.
Respectfully submitted,
CHERYL SWOPE LIECK
Chambers County District Attorney
/s/ Kathy Esquivel
KATHY ESQUIVEL
Assistant District Attorney
Chambers County, Texas
P.O. Box 1409
Anahuac, Texas 77514
(409) 267-2682
(409) 267-3105 FAX
SBN 24034432
kesquivel@co.chambers.tx.us
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been sent to
opposing counsel via email on ___17th _____ day of July, 2015.
/s/ Kathy Esquivel
KATHY ESQUIVEL
Assistant District Attorney
Chambers County, Texas
Rick Oliver
Attorney for Appellant