Cary, Stacy Stine

Opinion

PD-1341-1

COURT OF CRIMINAL APPEAL

AUSTIN, TEXA

Transmitted 8/11/2015 5:45:39 PI Accepted 8/12/2015 10:07:55 Al

IN THE ABELAc?er COURT OF COURT OF CRIMINAL APPEALS OF TEXAS

No. PD-1341-14 filed IN COURT OF CRIMINAL APPEALS

August 12, 2015

STACY STINE CARY, Appellant abelacosta, clerk

THE STATE OF TEXAS, Appellee XPC On Appeal from the Court of Appeals, Fifth District of Texas at Dallas Court of Appeals No. 05-12-01421-CR

APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE REPLY BRIEF BY TWO BUSINESS DAYS

Appellant Stacy Stine Cary respectfully moves for an extension of time to file her Appellant's Brief by two business days, until August 18, 2015. In support of this motion, she would respectfully show as follows:

1. The deadline for filing the Appellant's Brief is Friday, August 14, 2015.

2. Appellant seeks an extension of time of two business days, until Tuesday, August 18, 2015.

3. An extension is necessary because of appellate counsel's schedule and the complexity of the issues. Appellant's counsel has an evidentiary hearing in a

Unopposed Motion for Extension of Time—Page 1 criminal case on Thursday, August 13, 2015 and an all-day deposition in a civil case on Friday, August 14, 2015, that cannot be moved. Appellee also has a likely pretrial conference for a criminal trial in Hunt County, Texas on Monday, August 17, 2015, for a likely trial on August 24, 2015, for which he is preparing. APPELLEE, THE STATE OF TEXAS, DOES NOT OPPOSE THIS REQUESTED EXTENSION.

4. The Court has previously extended the time for this reply brief by 18 days. If granted, Ms. Cary will not request a further extension.

Respectfully submitted,

/s/ 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@j ohnhelmslaw.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.

Unopposed Motion for Extension of Time—Page 2

/s/ John M. Helms

John M. Helms

CERTIFICATE OF SERVICE

This certifies that a true and correct copy of this instrument has been served on counsel of record on August 11, 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