Paul Briones v. State ( 2015 )

ACCEPTED
01-14-00121-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/23/2015 9:10:48 AM
CHRISTOPHER PRINE
CLERK
No. 1-14-00121-CR
In the FILED IN
1st COURT OF APPEALS
Court of Appeals HOUSTON, TEXAS
For the 11/23/2015 9:10:48 AM
First District of Texas CHRISTOPHER A. PRINE
At Houston Clerk

No. 1268863
th
In 178 District Criminal Court
Harris County, Texas

PAUL BRIONES, 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 indecency with a child (CR 12). The jury
found appellant guilty and assessed punishment at 20 years in the
Institutional Division of the Texas Department of Criminal Justice (CR
50, 61). Appellant filed notice of appeal, and the court certified his right
to appeal (CR-67-68).
2. The State’s brief was due November 16, 2015. The State hereby requests
an extension for the filing of the State’s brief until December 16, 2015.
3. The following facts are relied upon to show good cause for an extension
of time to allow the State to file its brief:
The State has been working on and has filed the following briefs in the last
thirty days.
Dunn v. State
14-15-00340-CR
State’s Brief filed October 26, 2015
Gonzalez v. State
01-15-00395-CR
State’s Brief filed November 1, 2015
Marcopoulos v. State
01-15-00317-CR
State’s Brief to be filed November 23, 2015
Furthermore, the undersigned attorney has been assigned the following
briefs in addition to the brief in this cause number.
Tan v. State
01-15-00511-CR
State’s Brief due November 30, 2015
Carter v. State
01-14-01006-CR
State’s Brief due December 7, 2015
Uddin v. State
14-15-00083-CR
State’s Brief filed November 23, 2015
4. This is the State’s second request for an extension of time to file its brief.
WHEREFORE, the State prays that this Court will grant the requested
extension.
Respectfully submitted,
/s/ Kimberly Stelter
KIMBERLY STELTER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
Stelter_Kimberly@dao.hctx.net
TBC No. 19141400
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served by
efile.txcourts.gov to:
Daucie Schindler
Assistant Public Defender
1201 Franklin, 13th Floor
Houston, TX 77002
Daucie.Schindler@pdo.hctx.net
/s/ Kimberly Stelter
KIMBERLY STELTER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002-1923
(713) 755-5826
November 23, 2015