Page 1 of 4 No
. 01
- 14
- 00280
- CR
In the Court of Appeals For the First District of Texas At Houston

 No. 1 376587 In the 262nd Criminal District Court Of Harris County, Texas

 LOUIS STREDIC Appellant v. THE STATE OF TEXAS Appellee

 STATE’S SECOND 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 time in which to file the State’s brief in this case, and, in support thereof, presents the following: ACCEPTED 01-14-00280-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 1/5/2015 3:40:18 PM CHRISTOPHER PRINE

CLERKPage 2 of 4

1. In the 262nd Criminal District Court of Harris County, Texas, in cause
number 1 376587 , appellant was convicted of robbery in The State of Texas

v. Louis Stredic

. 2. O n March 13 , 2014, the trial court sentenced appellant to confinement in the Texas Department of Criminal Justice, Correctional Institutions Division,
for fifty years

. 3. On March 13, 2014 , appellant timely w ritten notice of appeal.
4. Appellant filed his appellate brief with this Court on November 2 , 2014

. 5. The State’s appellate brief is due on January 5 , 201 5

. 6. This is the State’s second request for an extension.
7. An extension of time in which to file the State’s appellate brief is requested
until February 5 , 201 5

. 8. The facts relied upon to explain the need for this extension are:
D uring the time in which the undersigned attorney has be en researching and preparing the State’s appellate brief for this case, she was al so researching and preparing the State’s appellate brief s in th e following case s assigned that are also to her:
i. William Johnson v. State of Texas ; No. 14

- 14

- 00475

- CR
ii. Ex parte Vidal Reyes ; No . 14

- 14

- 00440

- CR
iii. Ana Trujillo v. State of Texas ; No. 01

- 14

- 00397

- CR
iv. Ex parte Riku Melartin ; No. 14

- 14

- 00926

- CRPage 3 of 4 v. Jacinto Urapo v. State of Texas ; No. 14

- 14

- 00752

- CR

Consequently, the undersigned attorney has been unable to complete the State’s reply brief in this case in the time permitted despite due diligence , and t he requested extension of time i s necessary to permit the undersigned attorney to adequately investigate, complete , and file the State’s appellate brief for this cause.
9. The State’s motion is not for purposes of delay, but so that justice may be
done. WHEREFORE, the State prays that th is Court will grant an extension of
time until February 5 , 201 5 , for the undersigned attorney to complete and file the State’s appellate brief in this case

.
Respectfully submitted,

/ S / Melissa Hervey
M ELISSA P. H ERVEY Assistant District Attorne y Harris County, Texas State Bar No. 24053741 1201 Franklin Street , Suite 600 Houston, Texas 77002 Telephone (713) 755

- 5826 Fax (713) 755

- 5809 Hervey_Melissa@dao.hctx.netPage 4 of 4 CERTIFICATE OF SERVICE

This is to certify that the undersigned counsel has directed the e

- filing system eFile.TXCourts.gov to serve a true and correct copy of the foregoing document upon Cynthia Henley , appellant’s attorney of record on appeal, on January 5 , 201 5 , at the following e

- mail address, through the electronic service

s ystem provided by eFile.TXCourts.gov: cynthiahenley@yahoo.com

/ S / Melissa Hervey
M ELISSA P. H ERVEY Assistant District Attorney Harris County, Texas State Bar Number: 24053741 1201 Franklin Stree t , Suite 600 Houston, Texas 77002 Telephone (713) 755

- 5826 Fax (713) 755

- 5809 Hervey_Melissa@dao.hctx.net