IN THE COURT OF APPEALS FOR THE

FIRST DISTRICT OF TEXAS

NO. 01

- 15

- 00781

- CR

NO. 01

- 15

- 0078 2- CR

CHRISTOPHER CAVAZOS Appellant, On Appeal From the 184 th District Court of Harris County

V. Trial Cause Nos. 1402280 &

1443325

THE STATE OF TEXAS Appellee

FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE JUDGES OF SAID COURT:

ANGELA CAMERON, attorney of record for Appellant in the above cause,

would respectfully request the Court to grant h er motion to extend time for file brief.

In support of said motion, counsel would show unto the Court the following:

I.

This appeal lies from Appellant's convictions for intoxication manslaughter

and intoxication assault in The State of Texas v. Christopher Cavazos Cause Number

14 02280 and 1443325 in the 184 th District Court of Harris County. Cavazos pled to

both cases without an agreed recommendation and the cases were set for a PreSentence Investigation hearing. After a hearing, the trial court sentenced Appellant to

sixteen (16) years for intoxication manslaughter and nine (9) years for intoxication ACCEPTED
01-15-00782-CR
FIRST COURT OF APPEALS

HOUSTON, TEXAS
11/12/2015 10:28:53 AM
CHRISTOPHER PRINE

CLERKassault

. Notice of Appeal was timely filed

. The brief is due on Nove mber 12, 2015

.

No p rior extension s ha ve been requested

.

II.

Counsel will b e unable to file the brief in this cause as has bee n completing the

following tasks :

1. Preparing an d filing a brief in La wson Echeta v. State of Texas, Cause No.

01

- 15

- 00557

- CR which was filed on October 19, 2015

2. Investigation and filing of a Motion for New Trial in State of Texas v. Huey Jones

, Cause Number 1463572 in the 1 77 th District Court of Harris County. Counsel is continuing to investigate and prepare for a hearing

which is set on November 23 , 2015

.

3. Investigation and filing of a Motion for New Trial in State of Texas v. Joshua Barnett

, Cause Number 1451490 in the 230th District Court of Harris County. The Motion was filed on November 11, 2015. Counsel is continuing to investigate and prepare for a hearing which is set on

November 2 5 , 2015

.

4. Investigation i nto a possible Motion for New Trial in State of Texas v.

Daniel Sanders

, Cause Number 14 38488 in the 184th District Court of Harris County. The deadline for filing a Motion for New Trial is

Dec ember 3 , 2015.

5. The Appellate Division of the Harris County Public Defender ’ s Office has been short staffed requiring each attorney to be assigned more cases than normal

. Two individuals have been hired but will not begin working at the PDO until November 30, 2015 and December 7, 2015.

6. Counsel also has the briefs currently due in the following cases :

a. Troy Evans v. State of Texas, 01

- 15

- 00209

- CR which is due on November 23, 2015 after 2 prior 30 day extensions have been granted.b. Elijah Reed v. State of Texas, 01

- 15

- 00 481

- CR which is due on

November 2 0 , 2015 after one prior 30 day extension ha s been granted.

c. Jamon Walker v. State of Texas, 14

- 15

- 00 685

- CR which is due on

November 2 3 , 2015 after one prior 30 day extension ha s been granted.

V I.

An extension of time is necessary so that the brief can be timely filed. This

motion is not made for the purpose of delay.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this

Honorable Court will grant this request ed extension of time to file the Appellant's

Brief in the above cause and extend the time for filing the brief for at least thirty (30)

days.

Respectfully submitted,

Alexander Bunin

Chief Public Defender

/s/ 

## Angela Cameron

Angela Cameron

State Bar No. 00788672 Harris County Public Defender’s Office

1201 Franklin 13 th Floor Houston, Texas 77002

Tel: 713

- 368

- 0016 angela.cameron@pdo.h ctx.netCERTIFICATE OF SERVICE

I certify that on the 12 th day of November 201 5 a copy of the foregoing instrument

has been electronically served upon the State of Texas.

/s/ 

## Angela Cameron

ANGELA CAMERON