Toni Tavarez v. State

Opinion

ACCEPTED

01-15-00268-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

7/6/2015 3:57:20 PM

CHRISTOPHER PRINE

CLERK

IN THE

FIRST COURT OF APPEALS

OF TEXAS FILED IN 1st COURT OF APPEALS

HOUSTON, TEXAS

TONI TAVAREZ § 7/6/2015 3:57:20 PM § CHRISTOPHER A. PRINE VS. § CASE NO. 01-15-00268-CR Clerk

§

THE STATE OF TEXAS §

MOTION TO EXTEND TIME NWITHIN WHICH TO FILE APPELLATE BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

NOW COMES, TONI TAVAREZ, appellant in the above-styled and numbered cause, by and through her attorney of record, Daucie Schindler, 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.

Ms. Tavarez was charged with the felony offense of murder. On, March 12, 2015, Ms. Tavarez was convicted as charged and sentenced to fifty (50) years imprisonment in the Institutional Division of the Texas Department of Criminal Justice.

II.

Ms. Tavarez filed timely notice of appeal on March 12, 2015. Undersigned counsel, of the Harris County Public Defender’s Office was appointed to represent Ms. Tavarez on March 13, 2015.

III.

The appellate brief is due to be filed with the Court on or before July 6, 2015.

No previous extensions have been requested.

IV.

Undersigned counsel has been working simultaneously on appeal in State v.

Phillips, State v. Snavely, State v. Earvin, State v. Wiggins, and State v. Marks. Counsel is diligently working on the brief in this case, but requests additional time to research and confer with the client.

V.

This request is made not to delay the proceedings, but to ensure the Ms.

Tavarez is adequately represented.

WHEREFORE, PREMISES CONSIDERED, Ms. Tavarez respectfully prays that this motion be granted and that the Court permits an extension of time until August 5, 2015, to file the appellate brief.

Respectfully Submitted,

ALEXANDER BUNIN

Chief Public Defender

Harris County Texas

/s/ Daucie Schindler __________ DAUCIE SCHINDLER

Assistant Public Defender Harris County Texas

1201 Franklin, 13th Floor Houston, Texas 77002

(713) 274-6717

(713) 368-9278 Fax

Daucie.Schindler@pdo.hctx.net

Attorney for Appellant,

TONI TAVAREZ

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Appellant’s Motion to Extend Time Within Which to File Appellate Brief was e-mailed to the Appellate Division of the Harris County District Attorney’s Office on this 6th day of July, 2015.

/s/ Daucie Schindler__________ DAUCIE SCHINDLER