No. 14-15-00126-CR

No. 14-15-00127-CR

No. 14-15-00128-CR

No. 14-15-00129-CR

In the 

Court of Appeals 

For the 

Fourteenth District of Texas 

At Houston 



No. 1405266 

No. 1405276 

No. 1428986

No. 1428987

In the 232nd District Court 

Harris County, Texas 



JOSEPH HOENINGHAUS 

Appellant 

v.

THE STATE OF TEXAS

Appellee 



STATE’S MOTION FOR EXTENSION OF TIME

IN WHICH TO FILE APPELLATE BRIEF



TO THE HONORABLE COURT OF APPEALS OF TEXAS:

 COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.5(b)(1) and 

38.6(d) of the Texas Rules of Appellate Procedure, and files this motion for extension of 

ACCEPTED

14-15-00126-CR

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

4/20/2015 4:08:20 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 4/20/2015 4:08:20 PM CHRISTOPHER A. PRINE Clerk
time in which to file the State’s brief in this case, and, in support thereof, presents the 

following:

1. In the 232nd District Court of Harris County, Texas, in cause number 1405266,

on May 22, 2014, Appellant was convicted in The State of Texas v. Joseph Hoeninghaus.

2. For the offense of burglary of a habitation, his punishment was assessed at nine 

years in prison.

3. In the 232nd District Court of Harris County, Texas, in cause number 1405276,

on May 22, 2014, Appellant was convicted in The State of Texas v. Joseph Hoeninghaus.

4. For the offense of possession of a controlled substance, his punishment was 

assessed at nine years in prison.

5. In the 232nd District Court of Harris County, Texas, in cause number 1428986,

on May 22, 2014, Appellant was convicted in The State of Texas v. Joseph Hoeninghaus.

6. For the offense of burglary of a habitation, his punishment was assessed at nine 

years in prison.

7. In the 232nd District Court of Harris County, Texas, in cause number 1428987,

on May 22, 2014, Appellant was convicted in The State of Texas v. Joseph Hoeninghaus.

8. For the offense of unauthorized use of a vehicle, his punishment was assessed at 

nine years in prison.

9. Written notices of appeal were filed on February 2, 2015.

10. Appellant’s brief was filed with this Court on March 11, 2015.

11. The State’s brief was due to be filed with this Court on April 10, 2015.
12. An extension of time in which to file the State’s brief is requested until April 21, 

2015.

13. No previous extensions have been granted to the State.

14. The facts relied upon to explain the need for this extension are:

The State’s brief in this case is being prepared by the Chief of the Appellate 

Division. He has numerous other duties in that position. Therefore, additional 

time has been necessary in order to prepare the State’s brief.

WHEREFORE, the State prays that this Court will grant an extension of time until 

April 21, 2015, in which to file the State’s brief in these cases.

Respectfully submitted,

/s/ Alan Curry

ALAN CURRY

Assistant District Attorney

Harris County, Texas

1201 Franklin, Suite 600

Houston, Texas 77002

(713) 755-5826

TBC No. 05263700

curry_alan@dao.hctx.net
CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument has been mailed to the 

appellant at the following addresses on April 20, 2015:

Joseph Hoeninghaus

SPN # 02425262

Cell # 2G4

701 North San Jacinto

Houston, Texas 77002

/s/ Alan Curry

ALAN CURRY

Assistant District Attorney

Harris County, Texas

1201 Franklin, Suite 600

Houston, Texas 77002

(713) 755-5826

TBC No. 05263700

curry_alan@dao.hctx.net

Date: April 20, 2015