IN THE COURT OF APPEALS FOR THE 

FIRST DISTRICT OF TEXAS 

NO. 01-15-00781-CR

NO. 01-15-00782-CR

CHRISTOPHER CAVAZOS 

Appellant, 

On Appeal From the 184th

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 her 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 

1402280 and 1443325 in the 184th 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

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 11/12/2015 10:28:53 AM CHRISTOPHER A. PRINE Clerk
assault. Notice of Appeal was timely filed. The brief is due on November 12, 2015. 

No prior extensions have been requested.

II.

Counsel will be unable to file the brief in this cause as has been completing the 

following tasks: 

1. Preparing and filing a brief in Lawson 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 177th 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 25, 2015.

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

Daniel Sanders, Cause Number 1438488 in the 184th District Court of 

Harris County. The deadline for filing a Motion for New Trial is 

December 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, 01-15-00481-CR which is due on 

November 20, 2015 after one prior 30 day extension has been 

granted.

c. Jamon Walker v. State of Texas, 14-15-00685-CR which is due on 

November 23, 2015 after one prior 30 day extension has been 

granted.

VI.

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 requested 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 13th Floor 

Houston, Texas 77002

Tel: 713-368-0016

angela.cameron@pdo.hctx.net
CERTIFICATE OF SERVICE

I certify that on the 12th day of November 2015 a copy of the foregoing instrument 

has been electronically served upon the State of Texas. 

/s/ Angela Cameron

ANGELA CAMERON