Elijah Reed v. State ( 2015 )

ACCEPTED 01-15-00481-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 11/24/2015 6:34:27 AM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS NO. 01-15-00481-CR FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 11/24/2015 6:34:27 AM ELIJAH REED CHRISTOPHER A. PRINE Appellant, Clerk On Appeal From the 177th District Court of Harris County V. Trial Cause No. 1464705 THE STATE OF TEXAS Appellee SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE JUDGES OF SAID COURT: ANGELA CAMERON, attorney of record for Appellant in the above cause, would respectfully request the Court to grant her motion to extend time for file brief. In support of said motion, counsel would show unto the Court the following: I. This appeal lies from Appellant's conviction in The State of Texas v. Elijah Reed Cause Number 1464705 in the 177th District Court of Harris County. Reed was found guilty of theft over $200,000 and sentenced to thirty-five (35) years confinement in the Texas Department of Criminal Justice – Institutional Division. Notice of Appeal was timely filed. The brief was due on November 20, 2015. One prior extension has been granted. II. Counsel will be unable to file the brief in this cause as has been completing the following tasks: 1. Investigation and filing of a Motion for New Trial as well as preparation for a hearing in State of Texas v. Huey Jones, Cause Number 1463572 in the 177th District Court of Harris County. The trial court granted a new trial on punishment only on November 23, 2015. 2. Investigation and filing of a Motion for New Trial in State of Texas v. Joshua Barnett, Cause Number 1451490 in the 230th District Court of Harris County. The Motion was filed on November 11, 2015. Counsel is continuing to investigate and prepare for a hearing which is set on November 25, 2015. 3. Investigation into a possible Motion for New Trial in State of Texas v. Daniel Sanders, Cause Number 1438488 in the 184th District Court of Harris County. The deadline for filing a Motion for New Trial is December 3, 2015. 4. The Appellate Division of the Harris County Public Defender’s Office has been short staffed requiring each attorney to be assigned more cases than normal. Two individuals have been hired but will not begin working at the PDO until November 30, 2015 and December 7, 2015. 5. Counsel also has the briefs currently due in the following cases: a. Troy Evans v. State of Texas, 01-15-00593-CR which was due on November 23, 2015 after two prior 30 day extension has been granted. b. Jamon Walker v. State of Texas, 14-15-00685-CR which was due on November 23, 2015 after one prior 30 day extension has been granted. c. Christopher Cavazos v. State of Texas, 01-15-00781-CR & 01-15-00782- CR which is due on December 14, 2015 after one prior 30 day extension has been granted. VI. An extension of time is necessary so that the brief can be timely filed. This motion is not made for the purpose of delay. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court will grant this requested extension of time to file the Appellant's Brief in the above cause and extend the time for filing the brief for at least thirty (30) days. Respectfully submitted, Alexander Bunin Chief Public Defender /s/ Angela Cameron Angela Cameron State Bar No. 00788672 Harris County Public Defender’s Office 1201 Franklin 13th Floor Houston, Texas 77002 Tel: 713-368-0016 angela.cameron@pdo.hctx.net CERTIFICATE OF SERVICE I certify that on the 24th day of November 2015 a copy of the foregoing instrument has been electronically served upon the State of Texas. /s/ Angela Cameron ANGELA CAMERON