Jaqualien Grant v. State

Opinion

ACCEPTED 14-13-01078-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 2/20/2015 6:12:01 PM CHRISTOPHER PRINE CLERK

Cause Nos. 14-13-01077-CR and 14-13-01078-CR

IN THE COURT OF APPEALS FILED IN 14th COURT OF APPEALS FOR THE HOUSTON, TEXAS FOURTEENTH JUDICIAL DISTRICT OF TEXAS 2/20/2015 6:12:01 PM AT HOUSTON CHRISTOPHER A. PRINE Clerk

JACQUALIEN GRANT, Appellant

v.

THE STATE OF TEXAS, Appellee.

Appeal from Cause Nos. 13806096 and 1386097 In the 185th District Court of Harris County, Texas ______________________________________________

APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE SUPPLEMENTAL BRIEF _______________________________________________

TO THE HONORABLE JUSTICES OF THE FOURTEENTH DISTRICT COURT OF APPEALS:

Appellant, JACQUALIEN GRANT, by and through his Counsel of Record,

CARMEN M. ROE, files this Motion to Extend Time to File Supplemental Brief For

Appellant and in support shows this Court the following: I.

Appellant was convicted in the 185th District Court of Harris County, Texas, in

Cause No. 1386906 and 1386097, for the offense of aggravated kidnapping and sexual

assault. Punishment was assessed at life in the Texas Department of Criminal Justice

Institutional Division.

II.

The Appellant’s brief was filed April 15, 2014. The State’s brief was filed June

18, 2014. Oral Argument was granted and set for December 18, 2014. On December 12,

2014, this Court issued a letter-ordering Appellant to file a response in regards to

Appellant’s conviction in Cause No. 14-13-01087-CR. Thereafter, Appellant filed a

motion to postpone submission and extend time to file an Supplemental Brief. This

Court granted two motions to extend time and Appellant’s Supplemental Brief was now

due February 13, 2015.

III.

Appellant now requests a final extension of time until February 20, 2015 to file its

Supplemental Brief and attaches it to this motion. Counsel requests the additional

extension of because Counsel is a solo-practitioner with the following briefs due: United

States v. Gonzalo Mosso-De Jesus and State v. Frank Distefano. Counsel completed a

motion for new trial due in State v. Mashood Uddin, a petition for discretionary review

due in State v. Zachary Hernandez, and has oral argument scheduled in State v. Marcos Flores. For these reasons, counsel has been unable to submit the Appellant’s Brief on

the due date and hereby requests an extension of time. For all these reasons, Counsel is

requesting a final extension of time and attaches its supplemental brief to this filing.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable

Court extend the time for filing Appellant’s Supplemental Brief in this cause until

February 20, 2015.

RESPECTFULLY SUBMITTED,

/s/ Carmen M. Roe _________________________________ CARMEN M. ROE LAW OFFICE OF CARMEN M. ROE SBN: 24048773 440 Louisiana, Suite 900 Houston, Texas 77002 713.236.7755 Phone 713.236.7756 Fax ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing was served to the

Harris County District Attorney, Appellate Division, 1201 Franklin Street, Houston,

Texas 77002, on February 20, 2015.

/s/ Carmen M. Roe _____________________________ CARMEN M. ROE