Bridget Renae Miller v. State

Opinion

ACCEPTED

01-14-00930-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

4/8/2015 12:42:45 PM

CHRISTOPHER PRINE

CLERK

Cause No. 01-14-00930-CR

FILED IN

BRIDGET RENAE MILLER, * IN THE COURT 1st OF COURT OF APPEALS

APPEALS

Appellant * HOUSTON, TEXAS 4/8/2015 12:42:45 PM

*

VS. * FIRST DISTRICT CHRISTOPHER A. PRINE

Clerk

*

THE STATE OF TEXAS, * Appellee * HOUSTON, TEXAS

MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF

Comes now BRIDGET RENAE MILLER, through her attorney of record John J. Davis, and files this Motion For An Extension of Time in which to file Appellant's Brief pursuant to Rules 10.5(b) and 38.6(d) of the Texas Rules of Appellate Procedure. In support of this Motion, Appellant shows the Court the following:

I.

TRIAL COURT: 239th District Court of Brazoria County, Texas, Judge Pat Sebesta, presiding.

CAUSE NUMBER: 74,2 32 STYLE: The State of Texas vs. Bridget Renae Miller DATE OF JUDGMENT: November 10, 2014 CONVICTION (OFFENSE): Injury to a Child SENTENCE: Ninety-nine (99) years TDCJ-ID DEADLINE FOR FILING APPELLANT'S BRIEF: 8 April 2015

LENGTH OF TIME REQUESTED FOR EXTENSION: 18 May 2015 (40 days)

NUMBER OF PREVIOUS EXTENSIONS GRANTED: None

II.

REASONS FOR EXTENSION

Appellant's request for an extension is based upon the following facts:

On March 17, 2015, Appellant's counsel completed and submitted a brief to this Court in Docket Number 01-14-00727-

CR styled Alphonso Smith vs. The State of Texas.

The record in the instant case is comprised of sixteen (16) volumes, 9 of which are reporter's record and seven (7) of which are exhibts. The trial itself constitutes 1162 pages excluding exhibits.

In addition to this brief, this attorney is the defense counsel for the Brazoria County Drug Court which meets every week and requires additional time for client conferences. Counsel is also the appointed defense counsel at probation reviews in the 149th and 239th District Courts as well as the appointed defense counsel for the jail dockets in County Court at Law Number 1 of Brazoria County. The length of this record coupled with the settings and requirements of the drug court and the review and jail dockets have resulted in Counsel being unable to finish the brief by the stated deadline.

WHEREFORE, PREMISES CONSIDERED, Appellant prays the Court grant this MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF and extend the time for filing the Brief until 18 May 2015.

Respectfully submitted,

/s/ John J. Davis

John J. Davis

P.O. Box 787

2 05 N. Chenango

Angleton, Texas 77516-0787 SBN 05515500

Telephone: (979) 849-4362 d.attorne@sbcglobal.net

ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF was served to:

Jeri Yenne Criminal District Attorney Brazoria County Courthouse 111 East Locust, Suite 408A Angleton, Texas 77515 ATTENTION: David Bosserman VIA FACSIMILE (979) 864-1525

on the 8th day of April 2015 /s/ John J. Davi:

John J. Davis

Attorney for Appellant