Abner L. Washington

Opinion

ACCEPTED

01-14-00885-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

6/10/2015 1:33:10 PM

CHRISTOPHER PRINE

CLERK

No. 01-14-00885-CR

In the FILED IN Court of Appeals 1st COURT OF APPEALS HOUSTON, TEXAS

For the 6/10/2015 1:33:10 PM First Judicial District of Texas CHRISTOPHER A. PRINE At Houston Clerk

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No. 1430059

In the 248th District Court of Harris County, Texas

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ABNER L. WASHINGTON

Appellant

v.

THE STATE OF TEXAS

Appellee

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STATE’S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE APPELLATE BRIEF

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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 248th District Court of Harris County, Texas, in The State of Texas v.

Abner L. Washington, Cause Number 1430059, appellant was convicted of possession of a controlled substance. 2. Appellant was sentenced to sixty days incarceration in the Harris County Jail. 3. The State’s brief was due on June 10, 2015. 5. An extension of time in which to file the State’s brief is requested until July 10, 2015. 6. One 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 March 22, 2014;

b) Since the undersigned attorney was assigned this case, the attorney finished writing the State’s briefs in the following cases:

(1) Cause Number 01-14-00900-CR, Felicity Burris, Appellant v. The State of Texas, Appellee, which involved one point of error and two volumes of the reporter’s record and is due on May 13, 2015; and (2) Cause Number 01-14-00748-CR, James Lee Skinner, Appellant v. The State of Texas, Appellee, which involved three points of error and is due on May 18, 2015.

c) The undersigned attorney has also been assigned to engaged in the preparation of the State’s Brief in the following appellate cause numbers

(1) Cause Number 01-14-00772-CR, Thanh Hoang, Appellant v. The State of Texas, Appellee, which involves one point of error; and (2) 14-14-00874-CR, Charles Roberts, Appellant v. The State of Texas, Appellee, which involves three points of error.

d) Additionally, the undersigned attorney has also been out of the office last week from the flooding in Houston and from attending the Conference on Criminal Appeals in Austin.

WHEREFORE, the State prays that this Court will grant an extension of time until July 10, 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) 755-5826

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 June 10, 2015 through TexFile:

Sarah V. Wood Assistant Public Defender, Harris County 1201 Franklin Street, 13th Floor Houston, Texas 77002 sarah.wood@pdo.hctx.net

/s/ Carly Dessauer

________________________________________________________________________________________________________________________________________________________________________________________________________________________________

CARLY DESSAUER

Assistant District Attorney Harris County, Texas

1201 Franklin, Suite 600

Houston, Texas 77002

(713) 755-5826

State Bar No. 24069083

dessauer_carly@dao.hctx.net curry_alan@dao.hctx.net

Date: June 10, 2015