Blasdell, Brandon Scott

Opinion

PD-0162-14

COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

March 26, 2015 Transmitted 3/26/2015 3:49:54 PM Accepted 3/26/2015 3:58:48 PM ABEL ACOSTA

No. PD-0162-14 CLERK

BRANDON SCOTT BLASDELL § IN THE COURT OF §

V. § CRIMINAL APPEALS §

THE STATE OF TEXAS § AT AUSTIN, TEXAS

____________________________________________________

STATE'S MOTION FOR

EXTENSION OF TIME TO FILE BRIEF

____________________________________________________

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW the State of Texas, by the undersigned assistant district

attorney, and moves the Court for an extension of time to file its appellate brief in the

above-captioned case. The State would respectfully show the Court the following:

1. The appellant was convicted of the offense of aggravated robbery. His

punishment was assessed at imprisonment for 30 years.

2. This Court granted the appellant’s petition for discretionary review and the

appellant’s brief was filed on February 24, 2015.

3. The State’s brief is due to be filed in this Court on March 26, 2015.

4. The State has not previously requested an extension of time to file its brief.

5. The State hereby requests a thirty-day extension of time to file its brief,

until April 24, 2015.

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9. Good cause exists for the requested extension of time, for the following

reasons:

In the past 30 days, the undersigned counsel for the State has been required to prepare and file several written responses, including the State’s appellate brief in the Lauro Grimaldo Rincon v. The State of Texas, Case No. 14-14-00535-CR; the State’s appellate brief in Veronica Gonzalez v. The State of Texas, Case No. 09-14-00322-CR; the State’s answer to application for post-conviction writ of habeas corpus and proposed findings of fact and conclusions of law in Ex parte Kyle Clayton Ellisor, Case No. 11-02-01557-CR-(1); and the State’s answer to application for post-conviction writ of habeas corpus and proposed findings of fact and conclusions of law in Ex parte Jermond Dewayne Thompson, Case No. 13-05-05262-CR-(1).

THEREFORE, the State requests an extension of time to file its response until

April 24, 2015, in this case.

Respectfully submitted,

BRETT W. LIGON District Attorney Montgomery County, Texas

BRENT CHAPELL Assistant District Attorney Montgomery County, Texas S.B.T. No. 24087284 207 W. Phillips, Second Floor Conroe, Texas 77301 (936) 539-7800 (936) 788-8395 (fax) brent.chapell@mctx.org

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing motion was

mailed to the appellant, at the following address, on the date of the filing of the

original with the Clerk of this Court:

Mr. Jeremy S. Dishongh Attorney at Law 332 N. Main Conroe, Texas 77301

BRENT CHAPELL Assistant District Attorney Montgomery County, Texas