Gregory Charles Hurst v. State

Opinion

ACCEPTED 14-15-00539-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 10/22/2015 8:19:23 AM CHRISTOPHER PRINE CLERK

COURT OF APPEALS FOURTEENTH SUPREME JUDICIAL DISTRICT Houston, Texas FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS GREGORY CHARLES HURST, § 10/22/2015 8:19:23 AM APPELLANT § CHRISTOPHER A. PRINE § NUMBERS Clerk VS. § 14-15-00539-CR § § THE STATE OF TEXAS, § APPELLEE

SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANT BRIEF

Winifred Weber 2525 Bay Area Blvd. Suite 310 Houston, Texas 77058 SBN 01672500 Telephone: (281)488-9040 Facsimile: (281)488-9009 Electronic mail: winifredweber@gmail

ATTORNEY FOR APPELLANT TO THE HONORABLE FOURTEENTH COURT OF APPEALS:

Pursuant to Tex. R. App. P. 10.1 and 38.6(d), Appellant, GREGORY CHARLES

HURST, files this Second Motion to Extend Time to File Appellant Brief.

Appellant’s opening brief is currently due October 21, 2015.

Counsel for Appellant requests a 7-day extension of time to file his brief, making

the brief due October 28, 2015. This is the second request for extension of time to

file the opening brief.

In addition to the routine matters that counsel must attend to in daily practice, such

as a full criminal caseload requiring docket appearances, filings, and jail visits,

counsel for Appellant relies on the following reason, to explain the need for the

requested extension:

On this date, Appellant has brought a potential issue to the attention of

Appellant’s counsel and requested counsel to research said issue for Appellant’s

brief. Counsel believes one week is adequate time to research the issue and include it

in the brief, depending on the result of the research. Counsel for Appellant seeks this

extension of time to be able to adequately prepare Appellant’s brief. This request is

not sought for delay but so that justice may be done.

All facts recited in this motion are within the personal knowledge of the counsel

signing this motion; therefore no verification is necessary under Rule of Appellate

Procedure 10.2. PRAYER FOR RELIEF

For the reasons set forth above, Appellant requests that this Court grant this

Second Motion to Extend Time to File Appellant Brief and extend the Deadline for

Filing the Appellant’s Brief up to and including October 28, 2015. Appellant

requests all other relief to which he may be entitled.

Respectfully submitted,

/s/______________________ Winifred Bandy Weber Winifred Bandy Weber 2525 Bay Area Blvd. Suite 310 Houston, Texas 77058 SBN 01672500 Telephone: (281)488-9040 Facsimile: (281)488-9009 Electronic mail: winifredweber@gmail

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing Motion has been delivered by electronic email to the Galveston County District Attorney’s Office, Galveston, Texas on this the 21st day of October, 2015.

Winifred Bandy Weber /s/_______________________ WINIFRED WEBER