Jason A. Snavely v. State

Opinion

ACCEPTED

01-15-00185-cr

FIRST COURT OF APPEALS

HOUSTON, TEXAS

6/19/2015 10:13:00 AM

CHRISTOPHER PRINE

CLERK

IN THE

FIRST COURT OF APPEALS

OF TEXAS FILED IN 1st COURT OF APPEALS

HOUSTON, TEXAS

JASON SNAVELY § 6/19/2015 10:13:00 AM § CHRISTOPHER A. PRINE VS. § CASE NO. 01-15-00185-CR Clerk

§

THE STATE OF TEXAS §

MOTION TO EXTEND TIME WITHIN WHICH TO FILE APPELLATE BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

NOW COMES, JASON SNAVELY, appellant in the above-styled and numbered cause, by and through his attorney of record, Daucie Schindler, and respectfully moves the Court for an extension of time within which to file the appellate brief, and for cause would show the Court as follows:

I.

Mr. Snavely was charged with the felony offense of aggravated assault of a household member. On February 14, 2014, Mr. Snavely was convicted as charged and sentenced by the jury to fifty-five (55) years imprisonment in the Institutional Division of Texas Department of Criminal Justice.

II.

Mr. Snavely filed timely notice of appeal. Undersigned counsel, of The Harris County Public Defender’s Office was appointed to represent Mr. Snavely on February 19, 2015.

III.

The appellate brief is due to be filed with the Court on or before June 19, 2015.

One previous extension has been requested.

IV.

Undersigned counsel has been working simultaneously on appeal in State v.

Earvin, State v. Wiggins, State v. Tavarez, State v. Phillips, State v. Means, State v. Umanzor, and State v. Mays. Counsel is diligently working on the brief in this case, but requests additional time for the supplementation of the record and to research and confer with the client.

V.

This request is made not to delay the proceedings, but to ensure that Mr.

Snavely is adequately represented.

WHEREFORE, PREMISES CONSIDERED, Mr. Snavely respectfully prays that this motion be granted and that the Court permits an extension of time until July 20, 2015, to file the appellate brief.

Respectfully submitted,

ALEXANDER BUNIN

Chief Public Defender

Harris County Texas

/s/ Daucie Schindler

DAUCIE SCHINDLER

Assistant Public Defender Harris County Texas

1201 Franklin, 13th Floor Houston Texas 77002

(713) 368-0016

(713) 368-9278 (Fax)

Daucie.Schindler@pdo.hctx.net

Attorney for Appellant,

JASON SNAVELY

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Appellant’s Motion to Extend Time within Which to File Appellate Brief was e-mailed to the Appellate Division of the Harris County District Attorney’s Office on this 19th day of June, 2015.

/s/ Daucie Schindler

DAUCIE SCHINDLER