ACCEPTED 01-15-00765-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/2/2015 10:18:29 AM CHRISTOPHER PRINE CLERK IN THE FIRST DISTRICT COURT OF APPEALS NO. 01-15-00764-CR, 01-15-00765-CR, 01-15-00766-CR FILED IN CORY NICKERSON 1st COURT OF APPEALS HOUSTON, TEXAS APPELLANT On Appeal from Nos. 1404004,12/2/2015 1416652, 1459622 10:18:29 AM From the 176 District Court CHRISTOPHER A. PRINE th Harris County, Texas Clerk V. THE STATE OF TEXAS APPELLEE APPELLANT’S MOTION FOR EXTENSION TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS: COMES NOW, Cory Nickerson, and files this Motion to Extend Time to File Brief, and in support thereof, would respectfully show the Court the following: I. Appellant’s brief was due November 18, 2015. There have been no previous motions for extension of time to file Appellant’s Brief. II. Counsel requests an extension due primarily to the fact that she has been engaged in work in the Harris County Public Defender’s Office on many cases, include the following: Lenin Lopez, 01-13-01079-CR, reversed and set for rehearing in cause #1403196 Ruben Totten, PD-0483-15 (PDR granted) Hugo Pachas-Lunas, 01-14-00516-CR, etc. Michael Davila, 01-15-00560-CR Stephen Hopper, 14-15-00371-CR Domingo Medina, 01-15-00575-CR Kori Henegar, 14-15-00529-CR Craig Beal, 01-12-00896-CR Joseph Smith, 14-15-00625-CR Emanuel Hayes, 1408364 Research and writing in preparation for several cases for the trial division of the Harris County Public Defender’s Office. III. Appellant’s attorney requests this extension which is necessary so that the brief can be thoroughly written and timely filed. This motion is not made for the purpose of delay. PRAYER WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court grants this extension for an additional 30 days to January 2, 2015. Respectfully Submitted, ALEXANDER BUNIN Chief Public Defender Harris County, Texas /s/ Sarah V. Wood SARAH V. WOOD Assistant Public Defender Texas Bar Number 24048898 1201 Franklin, 13th Floor Houston, Texas 77002 Phone: (713) 368-0016 Fax: (713) 368-9278 Sarah.Wood@pdo.hctx.net Certificate of Service By my signature below, I hereby certify that a true and correct copy of the above and foregoing has been served upon the Harris County District Attorney's Office – Alan Curry, via the electronic filing service. /s/ Sarah V. Wood Sarah V. Wood