Narjes Modarresi v. State

Opinion

ACCEPTED 14-14-00427-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 4/2/2015 10:11:54 AM CHRISTOPHER PRINE CLERK

No. 14-14-00427-CR

In the FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS Court of Appeals 4/2/2015 10:11:54 AM CHRISTOPHER A. PRINE For the Clerk

Fourteenth District of Texas

At Houston _________________________________________________________

Trial Court Cause No. 1260243 In the 339th District Court of Harris County, Texas _________________________________________________________

NARJES MODARRESI, Appellant v. THE STATE OF TEXAS, Appellee

___________________________________________________________

MOTION FOR EXTENSION OF TIME TO FILE

VIVIAN R. KING State Bar No. 00784399 2202 Alabama St. Houston, Texas 77004 (713) 222-2019 Office (877) 753-6706 eFax

Appointed Attorney for Appellant

1 TO THE HONORABLE COURT OF APPEALS:

NOW COMES NARJES MODARRESI, the Appellant herein, and moves the

Court for an extension of time to file Appellant's Brief in this cause, pursuant to TEX. R.

APP. PROC. Rules 10.5 (b)(2) and 38.6(n), and in support thereof would show the Court

as follows:

I.

The Appellant in this cause was convicted by a jury of Capital Murder in the 339th District

Court of Harris County, Texas in cause number 1260243 and her sentence was assessed at

Life in Prison without Parole in the Texas Department of Corrections, Institutional

Division. Notice of Appeal was properly filed on May 22, 2014.

II.

A Motion for New Trial was filed, heard, and denied.

The Clerk’s record was properly filed.

The Reporter’s record was filed on October 23, 2014.

Appellant’s brief was due on November 22, 2014.

This is a voluminous record. The case is complicated.

III.

Appellant has filed several motions for continuance.

Appellant’s attorney is requesting an extension of time to file Appellant’s Brief to

April 2, 2015. Appellant’s brief is being filed along with this extension.

2 WHEREFORE, PREMISES CONSIDERED, the undersigned counsel, on behalf of

Appellant, respectfully prays that this Honorable Court grant this extension to April 2,

2015.

RESPECTFULLY SUBMITTED,

/s/ Vivian R. King VIVIAN R. KING Appointed Attorney for Appellant Texas Bar No. 00784399 2202 Alabama St. Houston, Texas 77004 (713) 222-2019 office (877) 753-6706 e Fax VivianRKing@msn.com Email

CERTIFICATE OF SERVICE

As Attorney of Record for Appellant, I do hereby certify that a true and correct copy of the above and foregoing document was emailed to Appellate Division and efiled with the office of the Honorable Devon Anderson, Harris County District Attorney, on March 12, 2015.

/s/ Vivian R. King VIVIAN R. KING