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 179 TH 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

CLERKTO 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 caus e, 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 179 th 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) 2first 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) 3III. Counsel feels that if the additional time is granted, the Brief in this cause will be filed timely. IV. This is the first (1 st ) 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) 4Certificate of Service I hereby certify that on this 5 th day of May, 2015, a true and correct copy of the foregoing motion was sent to t he 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 com puter software used to prepare the motion.

/s/ Allen C. Isbell ALLEN C. ISBELL

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