Shaun Deville Briggs v. State

Opinion

ACCEPTED

01-15-00269-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

5/18/2015 3:34:46 PM

CHRISTOPHER PRINE

CLERK

IN THE

FIRST COURT OF APPEALS

OF TEXAS

FILED IN

1st COURT OF APPEALS

SHAUN DEVELLE BRIGGS § HOUSTON, TEXAS § 5/18/2015 3:34:46 PM VS. § Case Number No. 01-15-00269-CR CHRISTOPHER A. PRINE

§ Clerk THE STATE OF TEXAS §

First Motion to Extend Time to File Brief Now comes Shaun Develle Briggs, appellant in the above-styled and numbered cause, by and through assistant public defender, Jani J. Maselli Wood, 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.

On February 18, 2015, Mr. Briggs was convicted of the offense of aggravated robbery and was sentenced to 15 years imprisonment in the Texas Department of Criminal Justice - Institutional Division. He was convicted in cause number1430016 in the 263rd District Court of Harris County, Texas, styled The State of Texas v. Shaun Develle Briggs.

II.

The brief is currently due May 14, 2015. No extensions have been requested.

III.

Undersigned counsel is requesting 30 days from that due date until June 14, 2015.

IV.

Counsel has been working on a murder appeal in State v. Joe Lee Bowden. The record is lengthy;

On April 30, 2015, counsel filed a PDR in State v. Joshua London;

On March 25, 2015, the Court of Criminal Appeals granted the State’s PDR in Osmin Peraza v. State, NOS. PD-0100 & PD-0101-15. The CCA ordered expedited briefing (15 days per side with no extensions of time permitted). Undersigned counsel filed the brief on April 23, 2015. The CCA then set argument for May 20, 2015. This is also requiring additional time to prepare for argument.

Additionally, in January 2015, counsel made plans to attend a wedding and graduation in Massachusetts from May 14-17, 2015. The tickets are nonrefundable.

V.

This request is made not to delay the proceedings, but to ensure that Mr. Briggs is adequately represented.

WHEREFORE, PREMISES CONSIDERED, Mr. Briggs respectfully prays that this undersigned counsel be designated as the attorney of record in this cause and that the Court permit an extension of time until June 14, 2015.

Respectfully submitted,

ALEXANDER BUNIN

Chief Public Defender

Harris County Texas

/s/ Jani Maselli Wood

_______________________

JANI J. MASELLI WOOD

Assistant Public Defender State Bar Number 00791195 Harris County Texas

1201 Franklin, 13th Floor Houston Texas 77002

(713) 368-0001

(713) 368-9278 (Fax)

Jani.Maselli@pdo.hctx.net

Attorney for Appellant,

Shaun Develle Briggs

CERTIFICATE OF SERVICE

Pursuant to Tex. R. App. Proc. 9.5, this certifies that on May 18, 2015, a copy of the foregoing was emailed to counsel for the state (through texfile.com) at the following address:

Alan Curry Assistant District Attorney 1201 Franklin Street, 6th Floor Houston, TX 77002 curry_alan@dao.hctx.net

/s/ Jani J Maselli Wood

___________________________________

JANI J. MASELLI WOOD