Alton Joseph Jolivette v. State

Opinion

ACCEPTED 01-15-00673-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/1/2015 9:17:00 AM CHRISTOPHER PRINE CLERK

IN THE COURT OF APPEALS OF TEXAS FIRST JUDICIAL DISTRICT FILED IN ALTON JOSEPH JOLIVETTE, JR. § 1st COURT OF APPEALS HOUSTON, TEXAS § CASE NOS.12/1/2015 01-15-00672-CR 9:17:00 AM VS. § 01-15-00673-CR CHRISTOPHER A. PRINE § 01-15-00674-CR Clerk THE STATE OF TEXAS §

MOTION TO EXTEND TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THIS COURT:

Appellant Alton Joseph Jolivette, through counsel, moves the Court to extend time to file his brief, due November 30, 2015, for the following reasons:

1. Counsel, Assistant Public Defender, Melissa Martin has been working on many cases including, but not limited to Humphrey v. State , 14-15-00226-CR; Hill v State, 01-14- 00945-CR; Bonds v. State, 01-15-00688-CR; Davison v. State, 14-14-00511-CR; and Cameron v. State, 14-15-00447-CR, as well as the instant case and has been unable to complete the brief despite due diligence.

2. This is the first request for an extension in this case.

In view of the foregoing, Mr. Jolivette asks the Court to extend the time to file his brief for 30 days, or up to and including December 30, 2015. This request is made in the interest of justice and effective assistance of counsel and not for purposes of delay. Respectfully submitted, ALEXANDER BUNIN Chief, Harris County Public Defender’s Office

/s/ Melissa Martin _________________________________ MELISSA MARTIN Assistant Public Defender TX. Bar No. 24002532 1201 Franklin St., 13th Fl. Houston, TX 77002 email: melissa.martin@pdo.hctx.net 713/274-6709 Fax 713/437-4319 CERTIFICATE OF SERVICE

I certify that a copy of the foregoing motion was electronically served on the Harris County District Attorney’s office on December 1, 2015.

/s/ Melissa Martin __________________________ Melissa Martin