Arturo Chavez, Jr. v. State

Opinion

ACCEPTED

01-14-00232-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS 3/27/2015 4:15:02 PM CHRISTOPHER PRINE

CLERK

NO. 01-14-00232-CR

IN THE COURT OF APPEALS

FILED IN

FOR THE FIRST JUDICIAL DISTRICT 1st COURT OF APPEALS HOUSTON, TEXAS HOUSTON, TEXAS

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3/27/2015 4:15:02 PM

CHRISTOPHER A. PRINE

ARTURO CHAVEZ Clerk Appellant

V.

STATE OF TEXAS Appellee

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On Appeal from the 338th Judicial District Court of Harris County, Texas - Trial Court No. 1338052 Honorable Brock Thomas

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MOTION FOR LEAVE AND EXTENSION OF TIME TO FILE REPLY BRIEF

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TO THE HONORABLE JUDGES OF SAID COURT:

Arturo Chavez, Appellant, respectfully requests leave of court and an extension of time to

file a reply brief. Appellant’s reply brief is filed at the same time as this motion. Appellant filed

his brief on December 11, 2014. The state filed its brief in response on February 2,

2015. According to Texas Rule of Appellant Procedure 38.6(c), Appellant’s reply brief was due

by February 22, 2015.

Replying to the state’s brief took considerably more time than anticipated. Counsel

believes that the reply brief will assist the Court in narrowing and addressing the issues presented

in this appeal. For these reasons, Appellant seeks leave to file his reply brief out of time.

Respectfully submitted,

DeGUERIN, DICKSON, HENNESSY & WARD

/s/Matt Hennessy Matt Hennessy State Bar No. 00787677 matt@deguerin.com 1018 Preston, 7th Floor Houston, Texas 77002 (713 223-5959 Telephone (713) 223-9231 Facsimile

Attorney for Appellant

CERTIFICATE OF SERVICE

This will certify that a true and correct copy of the foregoing Motion for Leave and for Extension of Time to File Reply Brief has been delivered to Alan Curry, Assistant District Attorney, Appellate Division, 1201 Franklin, Suite 600, Houston, Texas 77002, via electronic filing, on March 27, 2015.

/s/Matt Hennessy Matt Hennessy