Jason Charles Savoy v. State ( 2015 )

ACCEPTED
14-15-00637-cr
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
11/16/2015 10:53:19 AM
CHRISTOPHER PRINE
CLERK
IN THE
FOURTEENTH COURT OF APPEALS
OF TEXAS FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
JASON CHARLES SAVOY § 11/16/2015 10:53:19 AM
§ CHRISTOPHER A. PRINE
VS. § CASE NO. 14-15-00637-CR
Clerk
§
THE STATE OF TEXAS §
MOTION TO EXTEND TIME WITHIN WHICH TO FILE APPELLATE
BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
NOW COMES, JASON CHARLES SAVOY, 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. Savoy was charged with the felony offense of murder. On, July 20, 2015,
Mr. Savoy was convicted as charged and sentenced to forty (40) years imprisonment in
the Institutional Division of the Texas Department of Criminal Justice.
II.
Mr. Savoy filed timely notice of appeal and on July 29, 2015, undersigned
counsel, of the Harris County Public Defender’s Office was appointed to represent him
on appeal.
III.
The appellate brief is due to be filed with the Court on or before November 16,
2015. No previous extensions have been requested.
IV.
Undersigned counsel has been working simultaneously on the direct appeal in
Williams v. State, Tavarez v. State, Martinez v. State, Wiggins v. State, Marks v. State,
Edwards v. State and the PDR in Fletcher v. State. 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 the Mr. Savoy
is adequately represented.
WHEREFORE, PREMISES CONSIDERED, Mr. Savoy respectfully prays that this
motion be granted and that the Court permits an extension of time until December 16,
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) 274-6717
(713) 368-9278 Fax
Daucie.Schindler@pdo.hctx.net
Attorney for Appellant,
JASON CHARLES SAVOY
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 16th day of November,
2015.
/s/ Daucie Schindler__________
DAUCIE SCHINDLER