Cary, Stacy Stine

Opinion

PD-1341-14

COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 4/24/2015 2:13:36 PM Accepted 4/24/2015 2:28:16 PM ABEL ACOSTA

IN THE CLERK COURT OF COURT OF CRIMINAL APPEALS OF TEXAS

______________________________

No. PD-1341-14

_______________________________

April 24, 2015

STACY STINE CARY, Appellant

v.

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 APPELLANT’S BRIEF

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

file her Appellant’s Brief by thirty (30) days. In support of this motion, she would

respectfully show as follows:

1. The deadline for filing the Appellant’s Brief is April 24, 2015.

2. Appellant seeks a thirty-day extension.

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

since the time the PDR was granted, the complexity of the facts and issues, and the

fact that the Fifth Court of Appeals has now issued an opinion in the related case of

David Cary v. State of Texas, No. 05-13-01010-CR, in which the Court of Appeals

Unopposed Motion for Extension of Time--Page 1 reversed the appellant’s conviction, and this opinion should be addressed in the

initial brief. APPELLEE, THE STATE OF TEXAS, DOES NOT OPPOSE

THIS REQUESTED EXTENSION.

4. No previous extension has been sought or granted.

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@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 April 23, 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