Dowden, Christopher Toby

• Court: Court of Appeals of Texas
• Decided: January 2, 2015
• Docket: WR-82,103-01
• Status: Published

Opinion

WR-82, 103-01 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS January 2, 2015 Transmitted 1/2/2015 1:22:04 PM Accepted 1/2/2015 1:25:16 PM TO THE COURT OF CRIMINAL APPEALS ABEL ACOSTA CLERK

WR-82, 103-01

EX PARTE On Application for a Writ of Habeas Corpus Cause Number 1300886 in the 337th District Court from Harris County

CHRISTOPHER DOWDEN

APPLICANT’S MOTION TO EXTEND TIME TO FILE BRIEF

TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:

COMES NOW, CHRISTOPHER DOWDEN, and files this his Motion to Extend Time to File Brief, and in support thereof, would respectfully show the Court the following:

I. This Court ordered briefing in this case from both parties to be due on December 30, 2014. No previous extensions have been requested.

II. Applicant’s attorney requests this extension because in this past month, counsel has suffered a very unpleasant and lingering virus and counsel’s child has also been ill, which has disrupted counsel’s work schedule in addition to holiday obligations and counsel’s work on many cases including a trial setting on December 23, 2014. Counsel has also been working on the following matters:

 In re K.C., Juvenile Trial Court No. 2012-04759J  Craig Beal, 01-12-00896-CR  Abner Washington, 01-14-00885-CR  Forest Penton, 14-14-00406-CR  Rodney Robins, 01-14-00582-CR  Hugo Pachas-Luna, 01-14-00516-CR, et. seq. III. Appellee’s attorney requests this extension of 30 days, which is necessary so that the brief can be thoroughly written and timely filed. This motion is not made for the purpose of delay.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Applicant prays that this Honorable Court grants this requested extension of time to file the brief in the above cause and extend the time for filing to January 30, 2015.

Respectfully submitted,

ALEXANDER BUNIN Chief Public Defender Harris County, Texas

/s/ Sarah V. Wood SARAH V. WOOD Assistant Public Defender Harris County, Texas Texas Bar Number 24048898 1201 Franklin, 13th Floor Houston Texas 77002 713.368.0016 (phone) 713.368.9278 (fax) Sarah.Wood@pdo.hctx.net

CERTIFICATE OF SERVICE

By my signature below, I hereby certify that a true and correct copy of the above and foregoing Appellee’s Motion to Extend Time to File Brief has been served on Roe Wilson, Assistant District Attorney of Harris County, Texas via the electronic e-file system.

/s/Sarah V. Wood Sarah V. Wood