Guylann Barrow v. State

ACCEPTED
14-14-00680-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
2/3/2015 3:16:28 PM
CHRISTOPHER PRINE
CLERK
NO. 14-14-00680-CR
__________________________________________
FILED IN
In the Court of Appeals for the Fourteenth District of Texas at Houston, TexasOF APPEALS
14th COURT
___________________________________________ HOUSTON, TEXAS
2/3/2015 3:16:28 PM
GUYLANN BARROW V. THE STATE OF TEXASCHRISTOPHER A. PRINE
____________________________________________ Clerk
On appeal from the 300th District Court of Brazoria County, Texas, No. 72928
___________________________________________
APPELLANT'S MOTION FOR EXTENSION OF TIME
TO FILE APPELLATE BRIEF
_____________________________________________________
TO THE HONORABLE COURT OF APPEALS: Guylann Barrow, appellant, files
this Motion for Extension of Time to File Appellate Brief in this cause, and in support
shows the following:
1. Nature of Proceeding. This appeal arises out of a proceeding in the District
Court for the 300th Judicial District of Brazoria County, Texas.
2. Deadline for Filing Appellant’s Brief. The deadline to file Appellant’s Brief was
November 17, 2014.
3. Facts Relied Upon to Explain Need for Extension. The original deadline for
filing of Appellant’s Brief was November 17, 2014. An extended deadline expired
on January 26, 2015. Counsel for appellant has had three 1st degree felony trials
since the beginning of the year, and has also been confronted with a deadline for a
Petition for Discretionary Review to the Texas Court of Criminal Appeals. The
request for delay is attributed to counsel’s exceptionally busy trial schedule over
the preceding weeks.
4. Number of Previous Extensions Granted. One (1) previous extension has been
granted for Appellant in this case.
5. Prayer. WHEREFORE, appellant requests that this Court grant Appellant's
motion for extension of time to file brief of 60 days.
Respectfully submitted,
/s/David Ryan
DAVID RYAN
SBN: 00786412
6161 Savoy Dr., Suite 1116
Houston, Texas 77036
(713)223-9898 FAX (713) 223-8448
Attorney for Appellee
CERTIFICATE OF CONFERENCE
I, David Ryan, hereby certify that counsel for appellee was not opposed to Appellee’s
Motion for Extension of Time to File Appellate Brief as of February 2, 2015.
/s/David Ryan
DAVID RYAN
Bridget Holloway
Assistant District Attorney Harris County, Texas 1201 Franklin, St., Suite 600
Houston, Texas 77002 (fax)
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing motion has been served
on all counsel of record, on February 2, 2015.
_____________
DAVID M. RYAN