William Marks v. State ( 2015 )

ACCEPTED
14-15-00064-cr
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
10/19/2015 1:43:03 PM
CHRISTOPHER PRINE
CLERK
IN THE
FOURTEENTH COURT OF APPEALS
OF TEXAS FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
WILLIAM MARKS § 10/19/2015 1:43:03 PM
§ CHRISTOPHER A. PRINE
VS. § CASE NOs. 14-15-00064-CR,
Clerk
§ 14-15-00065-CR &
THE STATE OF TEXAS § 14-15-00066-CR
MOTION TO EXTEND TIME WITHIN WHICH TO FILE APPELLATE
BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
NOW COMES, WILLIAM MARKS, appellant in the above-styled and
numbered cause, by and through his attorney of record, Daucie Schindler, and
respectfully moves the Court for an extension of time within which to file the appellate
brief, and for cause would show the Court as follows:
I.
Mr. Marks was convicted of three counts of violating the private securities act on
January 7, 2015. That same day, this court assessed his punishment at a probated
sentence of one (1) year in the Harris County Jail in each count. Mr. Marks was
represented at trial by Brian Coyne, while the State was represented by Assistant District
Attorney Heyward Carter. The Honorable Judge Pam Derbyshire presided over the
entirety of the trial proceedings.
II.
Mr. Marks filed timely notice of appeal. Undersigned counsel, of The Harris
County Public Defender’s Office was appointed to represent Mr. Marks on January 22,
2015. Mr. Mark’s filed a Motion for new Trial on February 3, 2015. The Motion for
New Trial was denied by the trial court.
III.
The appellate brief is due to be filed with the Court on or before October 19,
2015. One previous extension has been requested.
IV.
Counsel has been working simultaneously on the Appellant’s Briefs in Tavarez
v. State, State v. Williams, State v. Edwards, State v. Rodriguez, and State v. Wiggins.
Additionally, counsel has been working on the Petition for Discretionary Review in
Fletcher v. State and the Motion for New Trial in State v. Branch. Counsel is diligently
working on the brief in this case, but requests additional time to research and confer
with the client.
V.
This request is made not to delay the proceedings, but to ensure that Mr. Marks
is adequately represented.
WHEREFORE, PREMISES CONSIDERED, Mr. Marks respectfully prays that this
motion be granted and that the Court permits an extension of time until November
18, 2015, to file the appellate brief.
Respectfully submitted,
ALEXANDER BUNIN
Chief Public Defender
Harris County Texas
/s/ Daucie Schindler
DAUCIE SCHINDLER
Assistant Public Defender
Harris County Texas
1201 Franklin, 13th Floor
Houston Texas 77002
(713) 368-0016
(713) 368-9278 (Fax)
Daucie.Schindler@pdo.hctx.net
Attorney for Appellant,
WILLIAM MARKS
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Appellant’s Motion
to Extend Time within Which to File Appellate Brief was e-mailed to the Appellate
Division of the Harris County District Attorney’s Office on this 19th day of October,
2015.
/s/ Daucie Schindler
DAUCIE SCHINDLER