Albert Lynch v. State ( 2015 )

ACCEPTED
01-15-00421-cr
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/20/2015 1:09:16 PM
CHRISTOPHER PRINE
CLERK
No.01-15-00421-CR
In the FILED IN
Court of Appeals 1st COURT OF APPEALS
HOUSTON, TEXAS
For the 11/20/2015 1:09:16 PM
First Judicial District of Texas CHRISTOPHER A. PRINE
At Houston Clerk

No. 1314602
In the 339th District Court of
Harris County, Texas

ALBERT LYNCH
Appellant
v.
THE STATE OF TEXAS
Appellee

STATE’S MOTION FOR EXTENSION OF TIME
IN WHICH TO FILE APPELLATE BRIEF

TO THE HONORABLE COURT OF APPEALS OF TEXAS:
COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.1(a)
and 38.6(d) of the Texas Rules of Appellate Procedure, and files this motion for
extension of time in which to file the State’s brief in this case, and, in support thereof,
presents the following:
1. In the 339th District Court of Harris County, Texas, in The State of Texas v.
Eric Samuel Tucker, Cause Number 1314602, appellant was charged with and
found guilty of capital murder.
2. Appellant was sentenced to incarceration for life.
3. The State’s brief was due on November 20, 2015.
5. An extension of time in which to file the State’s brief is requested until
December 21, 2015.
6. No previous extension has been requested by the State.
7. The facts relied upon to explain the need for this extension are:
a) The undersigned attorney was assigned this case on November 2, 2015.
b) Since assigned this case, the undersigned attorney has completed the State’s
brief in the following cases:
i) Cause number 14-14-01008-CR, Mary Koul v. The State of Texas;
ii) and Cause numbers 01-15-00324-CR and 01-15-00325-CR, Astin Chavers
Clark v. The State of Texas.
c) The undersigned attorney is currently engaged in the preparation of the
State’s brief in the following appellate cause numbers:
(1) Cause Number 01-14-00885-CR, Abner Washington v. The State of Texas;
(2) Cause Number 14-15-00595-CR, Ricardo Martinez v. The State of Texas;
(3) Cause Number 14-15-00167-CR, Carl Dion Lovings v. The State of Texas;
(4) and Cause Number 01-15-00274-CR, Eric Samuel Tucker v. The State of
Texas.
WHEREFORE, the State prays that this Court will grant an extension of time until
December 21, 2015 in which to file the State’s brief in this case.
Respectfully submitted,
/s/ Carly Dessauer
________________________________________________________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 274-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument will be served to
appellant’s attorney on November 20, 2015 through TexFile:
Wendell A. Odom, Jr.
Attorney
440 Louisiana Street, Suite 200
Houston, Texas 77002
wendellodom@aol.com
/s/ Carly Dessauer
________________________________________________________________________________________________________________________________________________________________________________________________________________________________
CARLY DESSAUER
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 274-5826
State Bar No. 24069083
dessauer_carly@dao.hctx.net
curry_alan@dao.hctx.net
Date: November 20, 2015