Miles, Kojuan J. ( 2015 )

PD-0847&0848-15 PD-0847&0848-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 7/16/2015 3:21:30 PM
Accepted 7/17/2015 3:20:07 PM
ABEL ACOSTA
No. ________ CLERK
In the
Texas Court of Criminal Appeals
At Austin

Nos. 14-14-00154-CR & 14-14-00155-CR
In the
Court of Appeals
For the
Fourteenth District of Texas
At Houston

Nos. 1323841 & 1390391
In the 185th District Court
Of Harris County, Texas

KOJUAN J. MILES
Appellant
V.
THE STATE OF TEXAS
Appellee

STATE’S MOTION FOR EXTENSION OF TIME WITHIN WHICH
TO FILE A PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE COURT OF CRIMINAL APPEALS:
THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 10.1, 10.5(b) and 68.2(c),
moves for an extension of time within which to file its reply to appellant’s brief on the
merits. In support of its motion, the State submits the following:
July 17, 2015
1. Appellant was convicted of the offense of sexual assault of a child and
sentenced to seven-years confinement. He also was convicted of the offense
of compelling prostitution and sentenced to twenty-years confinement. The
judge ordered the sentences to be served consecutively.
2. On June 16, 2015, the Fourteenth Court of Appeals affirmed the two
convictions, but ordered the deletion of the cumulation order.
3. The State’s petition for discretionary review (PDR) is due on July 16, 2015.
4. The State seeks a 15-day extension until July 31, 2015, to file its PDR.
5. This is the State’s first request for an extension.
6. The following facts are relied upon to show good cause for the requested
extension:
My completion of this PDR has been delayed by my
completion of three other appellate briefs this past month. I
also have five other appellate briefs due in the next two weeks.
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WHEREFORE, the State prays that this Court will grant the requested extension.
Respectfully submitted,
/s/ Dan McCrory
DAN MCCRORY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
Mccrory_daniel@dao.hctx.net
(713) 755-5826
TBC No. 13489950
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been emailed to the
following email addresses via TexFile:
Nicolas Hughes
Assistant Public Defender
Nicolas.hughes@pdo.hctx.net
/s/ Dan McCrory
DAN MCCRORY
Assistant District Attorney
Harris County, Texas
1201 Franklin, Suite 600
Houston, Texas 77002
(713) 755-5826
TBC No. 13489950
Date: July 16, 2015
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