Jason Charles Savoy v. State

Opinion

ACCEPTED 14-15-00637-cr FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 11/16/2015 10:53:19 AM CHRISTOPHER PRINE CLERK

IN THE FOURTEENTH COURT OF APPEALS OF TEXAS FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS JASON CHARLES SAVOY § 11/16/2015 10:53:19 AM § CHRISTOPHER A. PRINE VS. § CASE NO. 14-15-00637-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 CHARLES SAVOY, 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. Savoy was charged with the felony offense of murder. On, July 20, 2015,

Mr. Savoy was convicted as charged and sentenced to forty (40) years imprisonment in

the Institutional Division of the Texas Department of Criminal Justice.

II.

Mr. Savoy filed timely notice of appeal and on July 29, 2015, undersigned

counsel, of the Harris County Public Defender’s Office was appointed to represent him

on appeal. III.

The appellate brief is due to be filed with the Court on or before November 16,

2015. No previous extensions have been requested.

IV.

Undersigned counsel has been working simultaneously on the direct appeal in

Williams v. State, Tavarez v. State, Martinez v. State, Wiggins v. State, Marks v. State,

Edwards v. State and the PDR in Fletcher v. State. Counsel is diligently working on

the brief in this case, but requests additional time to research and confer with the client.

V.

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

is adequately represented. WHEREFORE, PREMISES CONSIDERED, Mr. Savoy respectfully prays that this

motion be granted and that the Court permits an extension of time until December 16,

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) 274-6717 (713) 368-9278 Fax Daucie.Schindler@pdo.hctx.net

Attorney for Appellant, JASON CHARLES SAVOY 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 16th day of November,

2015.

/s/ Daucie Schindler__________ DAUCIE SCHINDLER