Cody Crymes v. State

Opinion

ACCEPTED

01-15-00206-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS 7/17/2015 1:04:29 PM CHRISTOPHER PRINE

CLERK

No. 01-15-00206-CR

FILED IN

1st COURT OF APPEALS

IN THE COURT OF APPEALS HOUSTON, TEXAS 7/17/2015 1:04:29 PM

FIRST JUDICIAL DISTRICT CHRISTOPHER A. PRINE Clerk

HOUSTON, TEXAS

__________________________________________________________

No. 17166

IN THE 253RD DISTRICT COURT OF

CHAMBERS COUNTY, TEXAS

__________________________________________________________

CODY CRYMES § Appellant

v. §

STATE OF TEXAS § Appellee

__________________________________________________________

STATE'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF

__________________________________________________________

Cheryl Swope Lieck District Attorney Chambers County, Texas

Kathy Esquivel Assistant District Attorney Chambers County, Texas P.O. Box 1409 Anahuac, Texas 77514 (409) 267-2682 (409) 267-3105 kesquivel@co.chambers.tx.us

COMES NOW the State of Texas, by and through her Assistant District Attorney, Kathy Esquivel, and, pursuant to TEX. R. APP. PRO. 73, presents this Motion for Extension of Time. In support of the motion, the State submits the following:

1. The above case is on appeal from a plea of guilty in the 253rd Judicial District Court of Chambers County, Texas.

2. The State’s brief is currently due on July 17, 2015.

3. This is the State’s first Motion for Extension of Time.

4. Counsel for the State was preparing for another jury trial in the 253rd District Court and did not have adequate time to complete the brief in this case. Further, counsel for the State was recovering from an illness that required several days off from work.

5. The State requests that the time for filing the State’s Brief be extended by 14 days to July 31, 2015. The State requests this extension not for delay, but to see that justice is done.

WHEREFORE, PREMISES CONSIDERED, the State prays that this

Court grant the State’s Motion for Extension of Time and extend the due date of the

State’s Appellate Brief until July 31, 2015.

Respectfully submitted, CHERYL SWOPE LIECK Chambers County District Attorney

/s/ Kathy Esquivel KATHY ESQUIVEL Assistant District Attorney

Chambers County, Texas P.O. Box 1409 Anahuac, Texas 77514 (409) 267-2682 (409) 267-3105 FAX SBN 24034432 kesquivel@co.chambers.tx.us

CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument has been sent to opposing counsel via email on ___17th _____ day of July, 2015.

/s/ Kathy Esquivel KATHY ESQUIVEL Assistant District Attorney Chambers County, Texas

Rick Oliver Attorney for Appellant