NO. 14-15-00155-CR

NO. 14-15-00156-CR

IN THE COURT OF APPEALS

FOURTEENTH DISTRICT

HOUSTON, TEXAS

NO. 1385626

NO. 1385627

IN THE TRIAL COURT

179TH JUDICIAL DISTRICT

HARRIS COUNTY, TEXAS

LARRY TORRES § APPELLANT

VS. §

THE STATE OF TEXAS § APPELLEE

MOTION FOR EXTENSION OF TIME

FOR FILING APPELLANT'S BRIEF

ALLEN C. ISBELL

2016 Main St., Suite 110

Houston, Texas 77002

713/236-1000

Fax: 713/236-1809

STATE BAR NO. 10431500

COUNSEL ON APPEAL

ACCEPTED

14-15-00156-CR

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

5/5/2015 10:48:19 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 5/5/2015 10:48:19 AM CHRISTOPHER A. PRINE Clerk
TO THE HONORABLE COURT OF APPEALS:

COMES NOW LARRY TORRES, appellant, by and through his

appointed counsel on appeal, and respectfully requests this Honorable Court

grant an Extension of Time for Filing an Appellant's Brief. The present date

for filing the Brief is May 8, 2015, and it is respectfully requested that said time

be extended until July 7, 2015. For cause, appellant would show the Court as

follows:

I.

On February 12, 2015, appellant was convicted of Felon in Possession

of a Weapon in Cause No. 1385626 and Possession with Intent to Deliver a

Controlled Substance in Cause No. 1385627, in the 179th District Court of

Harris County, Texas entitled The State of Texas vs. LARRY TORRES and

was sentenced to fifteen (15) years confinement in Cause No. 1385626 and

twenty-five years confinement in Cause No. 1385627, both sentences to run

concurrently, in the Texas Department of Criminal Justice, Institutional

Division. No Motion for New Trial was filed. Written Notice of Appeal was

given February 12, 2015.

II.

Counsel is unable to timely file the Brief within the time period from the

c:\appeals\torres\ext. brief (cause nos. 1385626 & 1385627) 2
first extension of filing the Reporter’s Record for the following reasons:

1. Counsel recently relocated his office to 2016 Main St., Ste. 110,

Houston, Texas 77002 and is in the process of organizing his

office.

2. Counsel is presently working on the following Brief for Appellant:

Rivera v. State, No. 01-14-00957-CR;

3. Counsel is presently working on the following Petition for

Discretionary Review for Appellant: Nelson v. State, No. 01-13-

00769-CR;

4. Counsel is currently preparing for the following criminal trials:

• State vs. Davis, No. 1438664 (Evading Arrest)(set to begin

May 26, 2015)

• State vs. Hobbs, Nos. 1322693, 1322694, 1322764,

1322796, 1323767, 1324124, & 1324125 (Capital Murder

(Death Penalty), Agg. Sexual Assault, Aggravated

Kidnaping, Aggravated Assault, & Murder)(set to begin July

6, 2015) 

5. Counsel has recently represented the following in court: State vs.

Bonds, No. 1436427; State vs. Caplan, No. 1449686; State vs.

Chapman, Nos. 1945284, 1945285, & 1945286; State vs. Earls,

Nos. 1466223, 1466294, & 1466318; State vs. Hornsby, Nos.

1455466, 1466294, & 1466318; State vs. Lawrence, No.

1455567; State vs. Magee, Nos. 1392085, 1386835, 1387732, &

1386809; State vs. McWashington, No. 1446879; State vs.

Manning, Nos. 1462015, 1462939, & 1462989; State vs. Morris,

No. 1458287; State vs. Olajuwon, No. 1462553; State vs. Palmer,

Nos. 1419391 & 1420714; State vs. Peters, No. 1447571; State

vs. Quarrells, No. 1455220; State vs. Simmons, No. 1434147; 

State vs. Smith, No. 1436342; State vs. Terrell, No. 1426152; 

c:\appeals\torres\ext. brief (cause nos. 1385626 & 1385627) 3
III.

Counsel feels that if the additional time is granted, the Brief in this cause

will be filed timely.

IV.

This is the first (1st) extension requested.

V.

This motion is urged at the first opportunity as appellant is indigent and

will suffer irremediable harm if it is not granted.

WHEREFORE, PREMISES CONSIDERED, appellant prays that this

Honorable Court grant this extension of time in which to file the appellant's

Brief until July 7, 2015. 

Respectfully submitted,

/s/ Allen C. Isbell 

ALLEN C. ISBELL

2016 Main St., Suite 110

Houston, Texas 77002

713/236-1000

Fax No. 713/236-1809

STATE BAR NO. 10431500

email: allenisbell@sbcglobal.net

COUNSEL ON APPEAL

c:\appeals\torres\ext. brief (cause nos. 1385626 & 1385627) 4
Certificate of Service

I hereby certify that on this 5th day of May, 2015, a true and correct copy

of the foregoing motion was sent to the District Attorney's Office, Appellate

Division, and to Mr. Larry Torres, appellant.

/s/ Allen C. Isbell 

ALLEN C. ISBELL

Certificate of Compliance

The undersigned attorney on appeal certifies this motion is computer

generated and consists of 683 words. Counsel is relying on the word count

provided by the Word Perfect computer software used to prepare the motion.

/s/ Allen C. Isbell 

 ALLEN C. ISBELL

c:\appeals\torres\ext. brief (cause nos. 1385626 & 1385627) 5