Zachary Keith Hill v. State

Opinion

ACCEPTED

01-14-00945-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS 7/31/2015 10:45:17 AM CHRISTOPHER PRINE

CLERK

IN THE COURT OF APPEALS OF TEXAS FIRST JUDICIAL DISTRICT

FILED IN

ZACHARY HILL § 1st COURT OF APPEALS HOUSTON, TEXAS

§ 7/31/2015 10:45:17 AM vs. § Case No. 01-14-00945-CR CHRISTOPHER A. PRINE

§ Clerk THE STATE OF TEXAS §

MOTION TO EXTEND TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THIS COURT:

Appellant Zachary Hill, through counsel, moves the Court to extend time to file his brief, due July 30, 2015, for the following reasons: 1. Counsel, Assistant Public Defender, Melissa Martin has been working on many cases including, but not limited to Humphrey v. State , 14-15-00226-CR; Carter v. State, 01- 14-01006-CR; Gilder v. State, PD-0975-15; as well as the instant case and has been unable to complete the brief despite due diligence. 2. This is the first request for an extension in this case.

In view of the foregoing, Mr. Hill asks the Court to extend the time to file his brief for 30 days, or up to and including August 29, 2015. This request is made in the interest of justice and effective assistance of counsel and not for purposes of delay.

Respectfully submitted,

ALEXANDER BUNIN Chief, Harris County Public Defender’s Office

/s/ Melissa Martin

_________________________________

MELISSA MARTIN Assistant Public Defender TX. Bar No. 24002532 1201 Franklin St., 13th Fl. Houston, TX 77002 email: melissa.martin@pdo.hctx.net 713/274-6709 Fax 713/437-4319

CERTIFICATE OF SERVICE

I certify that a copy of the foregoing motion was electronically served on the Harris County District Attorney’s office on July 31, 2015.

/s/ Melissa Martin

_________________________________

Melissa Martin