Harold James Harris v. State

Opinion

ACCEPTED

04-14-00888-CR

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

5/4/2015 10:41:59 AM

KEITH HOTTLE

No. 04-14-00888-CR CLERK

IN THE COURT OF APPEALS FOR THE FOURTH JUDICIAL DISTRICT OF TEXAS, AT SAN ANTONIOFILED IN 4th COURT OF APPEALS

SAN ANTONIO, TEXAS

Harold James Harris, 5/4/2015 10:41:59 AM Appellant

KEITH E. HOTTLE

v. Clerk

The State of Texas, Appellee

On Appeal from the County Court at Law No. 1 of Bexar County in Cause No. 384759, the Hon. John Fleming, Judge Presiding

Motion for Extension of Time To File Appellant’s Brief on Appeal

TO THE HONORABLE FOURTH COURT OF APPEALS:

COMES NOW, Harold James Harris, Appellant in the above styled and numbered cause, by and through David A. Schulman, his undersigned attorney of record, and respectfully enters this “Motion for Extension of Time to File Appellant’s Brief on Appeal,” and in support of such Motion would show the Court:

I

Appellant was convicted of driving while intoxicated.

Punishment was assessed at 180 days in jail and a $1,000 fine.

The trial court imposed sentence on December 5, 2014. Notice of Appeal was timely filed with the clerk of the trial court the same day.

II

The deadline for filing Appellant’s Brief with the Court is May 6, 2015. Appellant’s request for an extension is based upon the inability of the undersigned attorney to finish research on the issues raised by the trial of the case. Said attorney would further show that he will require an additional forty-five (45) days in which to complete the research and prepare Appellant’s Brief on Appeal. This is Appellant’s first request for an extension of time in which to file his brief.

Prayer

WHEREFORE PREMISES CONSIDERED, Appellant prays this Honorable Court to grant his “Motion for Extension of Time to File Brief on Appeal,” and Order that the deadline for filing such be extended an additional forty-five (45) days, until June 22, or until such time as set by this Court.

Respectfully submitted,

____________________________________

David A. Schulman

Attorney at Law

1801 East 51st Street, Suite 365-474 Austin, Texas 78723

Tel. 512-474-4747

Fax: 512-532-6282

zdrdavida@davidschulman.com State Bar Card No. 17833400 Attorney for Harold James Harris

Certificate of Compliance and Delivery This is to certify that: (1) this document, created using

WordPerfect™ X7 software, contains 327 words, excluding those items permitted by Rule 9.4 (i)(1), Tex.R.App.Pro., and complies with Rules 9.4 (i)(2)(B) and 9.4 (i)(3), Tex.R.App.Pro.; and (2) on May 4, 2015, a true and correct copy of the above and foregoing “Motion for Extension of Time To File Appellant’s Brief on Appeal” was transmitted via the eService function on the State’s eFiling portal, to Laura E. Durbin (laura.durbin@bexar.org), cousel of record for the State of Texas.

______________________________________

David A. Schulman