Harold Earl Reed v. State

• Court: Court of Appeals of Texas
• Decided: April 19, 2016
• Docket: 01-15-01080-CR
• Status: Published

Opinion

ACCEPTED 01-15-01080-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 4/19/2016 3:18:41 PM CHRISTOPHER PRINE CLERK

CAUSE NO. 01-15-01080-CR

HAROLD EARL REED, § IN THE COURT OF APPEALS FILED IN 1st COURT OF APPEALS Appellant § HOUSTON, TEXAS VS. § IN HOUSTON, TEXAS 4/19/2016 3:18:41 PM § CHRISTOPHER A. PRINE THE STATE OF TEXAS, § Clerk 1st JUDICIAL DISTRICT Appellee

MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW, HAROLD EARL REED, Appellant, and files this Motion for

Extension of Time to File Appellant's Brief, pursuant to Rules 10.5(b) and 38.6(d),

Texas Rules of Appellate Procedure. In support of this Motion, Appellant would

show the following:

I.

Appellant’s brief was due to be filed on April 18, 2016. Counsel for Appellant

requires an extension of one (1) day within which to complete and file Appellant’s

brief in this cause. This is Appellant’s second request for extension of time.

II.

Counsel for Appellant has worked diligently on the brief since receiving the

record, but has been unable to complete it for the following reasons: 1. Counsel for Appellant’s office was closed on April 19, 2016 due to

the flash flood emergency in Harris County, Texas and surrounding areas.

III.

This request is not made for the purpose of delay, but rather this request is

made to allow counsel adequate time to prepare Appellant’s Brief. Appellant

moves this Court for an order granting an extension of one (1) day, or until April

19, 2016 for Appellant to submit the brief in this case.

WHEREFORE, PREMISES CONSIDERED, Appellant moves this Court

for an order granting an extension of one (1) day for Appellant to submit the brief

in this case.

Respectfully submitted,

/s/ Nicole DeBorde NICOLE DEBORDE TBA No. 00787344 712 Main Street, Suite 2400 Houston, Texas 77002 Telephone: (713) 228-8500 Facsimile: (713) 228-0034 Email: Nicole@BSDLawFirm.com

COUNSEL FOR APPELLANT, HAROLD EARL REED CERTIFICATE OF COMPLIANCE

Pursuant to Rule 9 of the Texas Rules Appellate Procedure, the undersigned

counsel of record certifies that the motion contains 481 words.

/s/ Nicole DeBorde NICOLE DEBORDE CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing Motion

for Extension of Time to File Appellant's Brief was delivered via email to Alan

Curry, (curry_alan@dao.hctx.net) to the Harris County District Attorney's Office,

Appellate Division, 1201 Franklin, Suite 600, Houston, Texas 77002 on this the 19th

day of April, 2016.

/s/ Nicole DeBorde NICOLE DEBORDE CAUSE NO. 01-15-01080-CR

HAROLD EARL REED, § IN THE COURT OF APPEALS Appellant § VS. § IN HOUSTON, TEXAS § THE STATE OF TEXAS, § 1st JUDICIAL DISTRICT

ORDER

On this the _____ day of _______________, 201___, came on to be heard the

Appellant's Motion for Extension of Time to File Appellant's Brief and the Court is

of the opinion that this Motion should be:

GRANTED, and the deadline for filing the Appellant's brief in Cause No. 01-

15-01080-CR is extended to ____________________, 201__.

DENIED, to which action of the Court the Appellant objects.

SIGNED this the _____ day of _______________, 201__.

__________________________________ JUDGE PRESIDING