Cary, Stacy Stine

• Court: Texas Supreme Court
• Decided: July 27, 2015
• Docket: PD-1341-14
• Status: Published

Opinion

FILED IN PD-1 341-1 COURT OF CRIMINAL APPEALS COURT OF CRIMINAL APPEAL AUSTIN, TEXA July 27, 2015 Transmitted 7/27/2015 12:00:00 Af Accepted 7/27/2015 8:13:45 Ar ABELACOSTA, CLERK ABEL ACOST. IN 1HE CLER COURT OF COURT OF CRIMINAL APPEALS OF TEXAS

No. PD-1341-14

STACY STINE CARY, Appellant

v. •WftV Kfc^" THE STATE OF TEXAS, Appellee

On Appeal from the Court of Appeals, Fifth District of Texas at Dallas Court of Appeals No. 05-12-01421-CR

APPELLANT'S UNOPPOSED FIRST MOTION TO EXTEND TIME TO FILE REPLY BRIEF

Appellant Stacy Stine Cary respectfully moves for an extension of time to

file her Appellant's Brief by until August 14,2015. In support of this motion, she

would respectfully show as follows:

1. The deadline for filing the Appellant's Brief is July 27, 2015.

2. Appellant seeks an extension of time of 18 days, until August 14,

2015.

3. An extension is necessary because of appellate counsel's schedule and

the complexity of the issues. Appellant's counsel finished a jury trial in

Greenville, Texas during the week of July 13, 2015, and he has been trying to

Unopposed Motion for Extension of Time—Page 1 catch up with other matters since then. Appellant's counsel has a hearing in

federal court in McAllen, Texas on Monday, July 27, 2015 and then is scheduled to

take his eleven-year-old special needs son to Europe and will return on the evening

of August 8, 2015. APPELLEE, THE STATE OF TEXAS, DOES NOT

OPPOSE THIS REQUESTED EXTENSION.

4. No previous extension has been sought or granted.

Respectfully submitted,

Isi John M. Helms John M. Helms Texas Bar No. 09401001 BRODEN, MICKELSEN, HELMS & SNIPES, LLP 2600 State Street Dallas, Tx 75204 Tel: (469)951-8496 Fax:(214)720-9594 john@johnhelmslaw.com

ATTORNEY FOR APPELLANT, STACY STINE CARY

CERTIFICATE OF CONFERENCE

Undersigned counsel has conferred with Joseph Corcoran, counsel for Appellee, the State of Texas, and the Appellee does not oppose this motion.

/s/ John M. Helms John M. Helms

Unopposed Motion for Extension of Time-Page 2 CERTIFICATE OF SERVICE

This certifies that a true and correct copy of this instrument has been served on counsel of record on July 25, 2015, as follows:

Joseph Corcoran Assistant Attorney General P.O. Box 12548 Capitol Station Austin, TX 78711 * DELIVERED VIA E-MAIL * /s/ John M. Helms John M. Helms

Unopposed Motion for Extension of Time—Page 3