Chance Roach v. State

Opinion

ACCEPTED

01-14-00392-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS 1/30/2015 3:41:11 PM CHRISTOPHER PRINE

CLERK

No. 01-14-00392-CR

In the FILED IN 1st COURT OF APPEALS

Court of Appeals HOUSTON, TEXAS for the 1/30/2015 3:41:11 PM First District of Texas CHRISTOPHER A. PRINE Clerk

At Houston

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No. 1394753

In the 185th District Court Of Harris County, Texas

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CHANCE ROACH Appellant v.

THE STATE OF TEXAS Appellee

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STATE’S SECOND MOTION FOR EXTENSION OF TIME IN WHICH TO FILE AN APPELLATE BRIEF 

TO THE HONORABLE COURT OF APPEALS OF TEXAS:

COMES NOW THE STATE OF TEXAS, in accordance with Rules

10.5(b)(1) and 38.6(d) of the Texas Rules of Appellate Procedure, and files this

motion for an extension of time in which to file the State’s brief in this cause, and,

in support thereof, presents the following:

1. On April 25, 2014, a jury convicted appellant of aggravated assault with a deadly weapon and sentenced him to 20 years in the Institutional Division of the Texas Department of Criminal Justice and a $10,000 fine.

2. Appellant filed a timely written notice of appeal on April 25, 2014.

3. The State’s brief was due on January 30, 2015.

4. An extension of time in which to file the State’s brief is requested until March 2, 2015.

5. The following facts are relied upon to show good cause for the requested extension:

i. The undersigned attorney has been engaged in the preparation of the State’s Brief in Cause No. 14-14-00139-CR, Isaac Smith, Appellant v. The State of Texas, Appellee.

ii. The undersigned attorney has been engaged in the preparation of the State’s Brief in Cause No. 01-14-00422-CR, Benjamin Maurine Sadler, Appellant v. The State of Texas, Appellee.

iii. The undersigned attorney has been engaged in the preparation of the State’s Brief in Cause No. 01-12-01175-CR, Mark Rascoe, Appellant v. The State of Texas, Appellee.

iv. The undersigned attorney has been engaged in the preparation of the State’s Brief in Cause Nos. 01-14-00072-CR & 01-14- 00073-CR, Larry Wayne Richard, Appellant v. The State of Texas, Appellee.

WHEREFORE, the State prays that this Court will grant an additional

extension of time until March 2, 2015 in which to file the State’s brief in this

cause.

Respectfully submitted,

/s/ Heather A. Hudson HEATHER A. HUDSON Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 State Bar No. 24058991 hudson_heather@dao.hctx.net curry_alan@dao.hctx.net

CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument has been submitted

for service by e-filing to the following address:

Sarah V. Wood Assistant Public Defender 1201 Franklin, 13th Floor Houston, Texas 77002 Tel: (713) 368-0016 Fax: (713) 368-9278 Sarah.Wood@pdo.hctx.net

/s/ Heather A. Hudson HEATHER A. HUDSON Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 State Bar No. 24058991

Date: January 30, 2015