Trey Foster v. State ( 2015 )

ACCEPTED 14-15-00497-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 10/2/2015 2:56:21 PM CHRISTOPHER PRINE CLERK IN THE COURT OF APPEALS FOR THE FOURTEENTH DISTRICT COURT OF APPEALS HOUSTON, TEXAS FILED IN NO. 14-15-00496-CR, 14-15-00497-CR 14thHOUSTON, COURT OF APPEALS TEXAS TREY FOSTER 10/2/2015 2:56:21 PM APPELLANT On Appeal from Cause Number 1374929 CHRISTOPHER A. PRINE From the 228 District Court Clerk th Harris County, Texas V. THE STATE OF TEXAS APPELLEE APPELLANT’S MOTION FOR EXTENSION TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF APPEALS: COMES NOW, Trey Foster, and files this Motion to Extend Time to File Brief, and in support thereof, would respectfully show the Court the following: I. The current deadline for filing Appellant’s Brief is September 21, 2015. There has been one previous motion for extension of time to file Appellant’s Brief. II. Counsel has been engaged in work in the Harris County Public Defender’s Office on many cases, including the following:  Lenin Lopez, 01-13-01079-CR, reversed and set for rehearing in cause #1403196  Felix Irizarry, 14-14-00827-CR  Darryle Robertson, 14-15-00132-CR  Ruben Totten, PD-0483-15  Domingo Medina, 01-15-00574-CR  Stephen Hopper, 14-15-00371-CR  Pete Rodriguez, 14-15-00339-CR  Craig Beal, 01-12-00896-CR  Kori Henegar, 14-15-00529-CR  Counsel has been researching and writing for several trial cases assigned to the Public Defender’s Office Trial Division. III. Appellant’s attorney requests this extension which is necessary so that the brief can be thoroughly written and timely filed. This motion is not made for the purpose of delay. PRAYER WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable Court grants this extension to November 2, 2015. Respectfully Submitted, ALEXANDER BUNIN Chief Public Defender Harris County, Texas /s/ Sarah V. Wood SARAH V. WOOD Assistant Public Defender Harris County, Texas Texas Bar Number 24048898 1201 Franklin, 13th Floor Houston, Texas 77002 Phone: (713) 368-0016 Fax: (713) 368-9278 Sarah.Wood@pdo.hctx.net CERTIFICATE OF SERVICE By my signature below, I hereby certify that a true and correct copy of the above and foregoing has been served upon the Harris County District Attorney's Office – Alan Curry, via the electronic filing service. /s/ Sarah V. Wood Sarah V. Wood