Rodrick Odell Williams v. State

Opinion

ACCEPTED 01-15-00493-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 9/4/2015 10:41:18 AM CHRISTOPHER PRINE CLERK

CAUSE NO. 01-15-00493-CR ____________________ FILED IN IN THE COURT OF APPEALS 1st COURT OF APPEALS HOUSTON, TEXAS FOR THE FIRST SUPREME JUDICIAL DISTRICT 9/4/2015 10:41:18 AM CHRISTOPHER A. PRINE AT HOUSTON Clerk ____________________ RODERICK ODELL WILLIAMS, Appellant, Vs. THE STATE OF TEXAS, Appellee ____________________ Appealed from the 180TH District Court Of Harris County, Texas Cause Number 1373609 ____________________

MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

____________________

DENA FISHER SBOT: 24034440 440 LOUISIANA, STE 200 HOUSTON, TX 77002 P: 713.222.2201 F: 713.224.2815 d2f@sbcglobal.net TO THE HONORABLE FOURTEENTH COURT OF APPEALS:

Pursuant to TEX. R. APP. P. 10.1 and 38.6(d), the Appellant, RODRICK ODELL

WILLIAMS, files this Motion to Extend Time to File Appellant’s Brief.

Appellant’s opening brief is currently due on AUGUST 17, 2015.

Counsel for Appellant requests a 60-day extension of time to file its brief, making the brief

due on OCTOBER 18, 2015. This is the first request for extension of time to file the opening brief.

Counsel for Appellant relies on the following reasons, in addition to the routine matters

that counsel must attend to in daily practice, to explain the need for the requested extension:

1. The Reporter’s Record in this case is eight volumes long. Counsel requests additional time to read the voluminous record and to identify all relevant issues for appeal.

2. Counsel for Appellant has had the following matters set for trial or hearings in the last thirty days:

State of Texas v. Ramirez, Cause No. 1987404 – an Assault Family Violence trial, tried to a jury on 08/25/15. State of Texas v. Tello, Cause No. 1355280 – Felony Crim Misch trial State of Texas v. Galvan, Cause No. 201403647J – Aggravated Assault w/Deadly Weapon trial

Counsel for Appellant seeks this extension of time to be able to prepare a cogent and

succinct brief to aid this Court in its analysis of the issues presented. This request is not sought

for delay but so that justice may be done.

All facts recited in this motion are within the personal knowledge of the counsel signing

this motion, therefore no verification is necessary under Rule of Appellate Procedure 10.2.

PRAYER FOR RELIEF

For the reasons set forth above, Appellant requests that this Court grant this Motion to

Extend Time to File Appellant’s Brief and extend the Deadline for Filing the Appellant’s Brief.

Appellant prays for all other relief to which it may be entitled. Respectfully submitted,

/s/ Dena Fisher DENA FISHER SBOT: 24034440 440 LOUISIANA, STE 200 HOUSTON, TX 77002 P: 713.222.2201 F: 713.224.2815 d2f@sbcglobal.net Counsel for Appellant

CERTIFICATE OF SERVICE

I certify that on September 4, 2015, a true and correct copy of the forgoing motion was

delivered to the Harris County District Attorney’s Office by efile.

/s/ Dena Fisher DENA FISHER SBOT: 24034440 Counsel for Appellant