Rivers, Warren D.

Opinion

AP-77,051

COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 5/12/2015 3:18:46 PM May 12, 2015 Accepted 5/12/2015 3:21:45 PM No. AP-77,051 ABEL ACOSTA CLERK

In the

Texas Court of Criminal Appeals at Austin

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No. 0475122

In the 228th District Court Harris County, Texas

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WARREN DARRELL RIVERS

Appellant

V.

THE STATE OF TEXAS

Appellee

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APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE APPELLATE BRIEF

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TO THE HONORABLE COURT OF APPEALS:

APPELLANT, pursuant to TEX. R. APP. P. 10.1, 10.5(b) and 38.6(d), moves for an

extension of time within which to file its appellate brief. In support of its motion, appellant

submits the following:

1. Appellant was charged with capital murder. 2. A jury convicted appellant of the charged offense. In accordance with the jury’s answers to the special issues, the court sentenced appellant to death on November 18, 2014.

3. Notice of appeal was filed on November 18, 2014. 4. Appellant’s brief is due on May 18, 2015.

5. Appellant seeks an extension to file his brief until November 18, 2014.

6. The following facts are relied upon to show good cause for the requested extension:

a. The record in this case is voluminous, consisting of 32 volumes and many exhibits.

b. Appellant’s motion is not for purposes of delay, but so that justice may be done.

WHEREFORE, the State prays that this Court will grant the requested extension.

Respectfully submitted,

/s/PATRICK MCCANN PATRICK MCCANN SBN 00792680 MANDY MILLER SPN 24055561 Attorneys for appellant 909 Texas Ave., Ste. 205 Houston, TX 77022 PHONE (713) 223-3805 FAX (281) 667-3352 writlawyer@justice.com mandy@mandymillerlegal.com

3

CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument has been delivered via

electronic mail to the following address:

Alan Curry curry_alan@dao.hctx.net /s/PATRICK MCCANN PATRICK MCCANN SBN 00792680 MANDY MILLER SPN 24055561 Attorneys for appellant 909 Texas Ave., Ste. 205 Houston, TX 77022 PHONE (713) 223-3805 FAX (281) 667-3352 writlawyer@justice.com mandy@mandymillerlegal.com