NO. 01-15-00409-CR

IN THE 

COURT OF APPEALS FOR THE FIRST SUPREME JUDICIAL DISTRICT OF TEXAS 

AT HOUSTON 

.................................................................................................................................... 

TRIAL COURT NO. 1299015

IN THE 209TH DISTRICT COURT 

OF HARRIS COUNTY, TEXAS 

.................................................................................................................................... 

CURTIS SYLVESTER BABERS, APPELLANT 

V.

THE STATE OF TEXAS, APPELLEE 

.................................................................................................................................... 

APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF 

.................................................................................................................................... 

 Charles Hinton 

 P.O. Box 53719 

 Houston, Texas 77052-3719

 832-603-1330

 chashinton@sbcglobal.net 

 SBOT #09709800 

 Attorney for Appellant 

ACCEPTED

01-15-00409-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

9/21/2015 3:55:32 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 9/21/2015 3:55:32 PM CHRISTOPHER A. PRINE Clerk
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS

FOR THE FIRST SUPREME JUDICIAL DISTRICT:

Comes now appellant, Curtis Sylvester Babers, pursuant to TEX. R. APP. 

PROC. 10.5(b) and 38.6 and moves the Court for an extension of time to file 

appellant's brief, and in support shows the following:

(A) the deadline for filing appellant's brief is September 28, 2015.

(B) the length of the extension sought is until October 28, 2015.

(C) the facts relied upon to reasonably explain the need for an extension 

are:

Appellant's attorney has been preparing for jury trial in the following cases:

1. The State of Texas vs. Depachej Johnson, cause numbers 1307808 

(burglary of a habitation) and 1346275 (aggravated robbery) set for jury trial the

week of September 14, 2015. Pre-trials motions were heard on September 15, 

2015 and both cases were disposed of by way of a plea bargain agreement.

2. The State of Texas vs. Marvin Windom, cause numbers 1342650 

(Aggravated Assault-habitual indictment) and 1342651 (Burglary of a Habitationhabitual indictment) set for jury trial the week of October 5, 2015

3. The State of Texas vs. Russell Loge, cause number 1181851 (aggravated 

sexual assault of a child) set for jury trial the week of October 19, 2015.
4. The State of Texas vs. Jaquan Bogany, cause number 1361283 (Murder) 

set for jury trial the week of October 19, 2015.

(D) One previous extension has been granted.

Wherefore, undersigned counsel prays this honorable court to extend the 

time for filing appellant's brief until October 28, 2015.

Respectfully submitted,

/s/Charles Hinton

Charles Hinton

P.O. Box 53719

Houston, Texas 77052-3719

832-603-1330

chashinton@sbcglobal.net

SBOT #09709800

Attorney for Appellant

CERTIFICATE OF SERVICE

I certify that a copy of this motion has been electronically served upon Alan

Curry, Chief Prosecutor, Appellate Division, Harris County District Attorney's 

Office, 1201 Franklin St., Ste. 600, Houston, Texas 77002 on September 21, 2015.

/s/Charles Hinton

Charles Hinton
CERTIFICATE OF COMPLIANCE

Appellant certifies that the word count of this document is 402.

/s/Charles Hinton

Charles Hinton