No. 01 -14-00 748

- CR

In the Court of Appeals For the First Judicial District of Texas At Houston

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No. 1315689 In the 183rd District Court of Harris County, Texas

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J AMES L EE S KINNER Appellant

v. T HE S TATE OF T EXAS Appellee

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STATE’S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE APPELLATE BRIEF

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TO THE HONORABLE COURT OF APPEALS OF TEXAS:
COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.1(a)
and 38.6(d) of the Texas Rules of Appellate Procedure, and files this motion for
extension of time in which to file the State’s brief in this case, and, in support thereof,
presents the following: ACCEPTED 01-14-00748-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 4/17/2015 9:30:15 AM CHRISTOPHER PRINE

CLERK1. In the 1 8 3rd District Court of Harris County, Texas, in State v. James Lee

Skinner , Cause N umbers 1315689 , appellant was charged with possession of
methamphetamine, between 4 and 400 grams, with intent to deli ver

.

2. The court sentenced appellant to 10 years deferred adjudication

.
3. The State’s brief i s due on April 1 7 , 201 5

.
5. An extension of time in which to file the State’s brief is requested until May 18
,
201 5

.
6. No previous extension ha s been requested by the State.

7. The facts re lied upon to explain the need for this extension are:
a) The undersigned attorney was assigned this case on April 13 , 2015.
b) T he undersigned attorney recently finished writing the State’s brief s in the
following case :
(1) Cause Number 14

- 14

- 00 473

- CR, Jimmy Earl Va n

- Cleave , Appellant v. The
State of Texas, Appellee , which involves three points of error and three
volumes of the reporter’s record and that was filed on April 3, 2015 ;
(2) and Cause Number 14

- 14

- 00910

- CR, Ex parte Erik Montes de Oca

- Orozco
, which involved two points of error and one volume of the reporter ’ s record and that was filed on April 15, 2015

. c) The undersigned attorney was also recently preparing for oral argument in

Cause Number 01

- 1 3

- 00 931

- CR, Melissa Dromgoole , Appellant v. The State of
Texas, Appellee , that was held on April 8, 2015.d) The undersigned attorney is also currently engaged in the preparation of the

State’s Brief in the following appellate cause numbers:
(1) Cause Number 14

- 14

- 00 874

- CR, Charles Roberts , Appellant v. The State of
Texas, Appellee , which involves three points of error and seven volumes
of the reporter’s record ; and
(2) Cause Number 01

- 14

- 00 9 0 0

- CR, Felicity Burris , Appellant v. The State of
Texas, Appelle e , which involves one points of error and one volume of
the reporter’s record

. WHEREFORE, the State prays that this Court will grant an extension of time until
May 18 , 201 5 in which to file the State’s brief in this case.
Respectfully submitted,

/s/ 

# Carly Dessauer

______________________ __________________________________________ ___________________________________________________ _____________________________________________________________________________________________________________ C ARLY D ESSAUER Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 H ouston, Texas 77002 (713) 755

- 5826 State Bar No. 24069083 dessauer_carly@dao.hctx.netCERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument will be serv ed to
appellant’s attorney on April 17, 2015 through TexFile :

Norman J. Silverman Attorney at Law 917 Franklin, 4 th Floor Houston, Texas 77002 lawyernorm@msn.com /s/ 

# Carly Dessauer

______________________ ___

__________________________________________________________________________________________ _____________________________________________________________________________________________________________ C ARLY D ESSAUER Assistant District Attorney Harris Cou nty, Texas 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755

- 5826 State Bar No. 24069083 dessauer_carly@dao.hctx.net curry_alan@dao.hctx.net Date : April 17, 2015