Nayajah Niya Davis v. State

Opinion

ACCEPTED 14-15-00345-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 10/8/2015 3:29:50 PM CHRISTOPHER PRINE CLERK

CASE NO. 14-15-00345-CR

IN THE 14TH COURT OF APPEALS FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS OF THE STATE OF TEXAS 10/8/2015 3:29:50 PM CHRISTOPHER A. PRINE Clerk

THE STATE OF TEXAS, APPELLEE

v.

NAYAJAH NIYA DAVIS, APPELLANT

Appealed from the 262nd Judicial District Court Harris County, Texas Trial Cause No. 1412475

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

TO THE HONORABLE COURT OF APPEALS:

Comes now, Appellant, Nayajah Niya Davis, and files this, her motion for extension

of time to file Appellant’s Brief on the Merits. The Appellant has neither requested nor been

granted a previous extension of time to file Appellant’s brief.

The facts reasonably relied upon to explain the need for an extension of time are as

follows:

The issue(s) before the Court is/are believed, by the Appellant, to be of tremendous

importance. The issue involves a great deal of research on a number of issues involving Brady/exculpatory materials, intelligent and knowing waivers of certain constitutional

rights, and issues related to subpoena(s) and protective orders.

Additionally, the Appellant’s Attorney is currently finalizing appellate briefs in

COA No. 10-15-00155-CR; Ester Porras Natividad v. The State of Texas and COA No. 10-15-

00007-CR; Yvonne Carol Lindsey v. The State of Texas.

Counsel for Appellant respectfully requests the Honorable Court to grant a ninety

(90) day extension, or in the alternative a sixty (60) day extension in order that the

Appellant can procure the money needed to obtain the Court Reporter’s Record and allow

for her attorney to properly review the record and prepare an appropriate brief addressing

the issues anticipated to be raised.

Respectfully submitted,

/s/ J. Paxton Adams _______________________________ J. Paxton Adams Attorney at Law SBN: 24042459 1113 Twelfth Street Huntsville, Texas 77340 Tel. (936) 291-9900 Fax (936) 291-9903 ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE I do hereby certify that a copy of the foregoing Appellant’s Motion for Extension of Time to File Appellant’s Brief was forwarded to the following, on this the 8th day of October, 2015.

/s/ J. Paxton Adams ___________________________ J. Paxton Adams