No. 05-15-00034-CR

No. 05-15-00035-CR

No. 05-15-00107-CR

IN THE COURT OF APPEALS

FOR THE FIFTH DISTRICT OF TEXAS

AT DALLAS

SUMMER RAE HARRIS,

Appellant

v.

THE STATE OF TEXAS,

Appellee

On Appeal from the

194th Judicial District Court

Dallas County, Texas

Trial Nos. F-14-60100, F-13-25326, F-13-25357

MOTION TO FILE BRIEF TENDERED

Christian T. Souza

SBN: 00785414

Attorney for Appellant

4303 N. Central Expressway

Dallas, Texas 75205

Tel. (214) 862-7462

Fax (214) 696-0867

E-Mail: ctsouza@gmail.com

ACCEPTED

05-15-00107-CR

FIFTH COURT OF APPEALS

DALLAS, TEXAS

6/1/2015 12:00:00 AM

LISA MATZ

CLERK

 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 5/31/2015 5:07:15 PM LISA MATZ Clerk
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TO THE HONORABLE COURT OF APPEALS:

COMES NOW Appellant Summer Rae Harris and submits this 

motion to file brief tendered in Appeal Nos. 05-15-00034-CR (theft enhanced), 

05-15-00035-CR (forgery) and 05-15-00107-CR (forgery) pursuant to the Texas 

Rules of Appellant Procedure. TEX. R. APP. P. 10.1, 10.5, 38.6, 38.8. 

I.

The record was completed in No. 05-15-00034-CR on March 30, 2015.

On April 30, 2015, Appellant filed his first motion for extension of time to file 

the Brief for Appellant on all three cases. On May 1, 2015, this Court granted 

Appellant’s motion, allowing until May 29, 2015 in all three cases. The record 

was completed in 05-15-00035-CR and in 05-15-00107-CR when the Clerk’s 

Records in those cases were filed on May 19, 2015. Appellant has tendered his 

Brief for Appellant on May 31, 2015. 

II.

In addition to having an incomplete record in two of the cases until 

May 19, 2015, counsel has had conflicting obligations including as follows

since May 1, 2015: (1) preparation including witness contacts for hearing in Ex 

parte Daniel Perez, set in the 292nd Judicial District Court in Dallas County for 

May 22, 2015, with the State advising on May 5, 2015 that it desired a reset,

and with case reset for June 26, 2015; (2) appeal bond reduction hearing in the 
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trial court on May 5, 2015 in connection with the appeals at bar; (3) 

investigation and motion concerning supplementation of the record Jorge 

Villarreal-Flores v. United States of America, Appeal No. 14-11241, with motion 

filed on May 8, 2015; (4) Brief for Appellant in Appeal Bond Appeal in 

Theodore Roosevelt Arthur v. State, Appeal No. 05-15-00452-CR, an accelerated 

appeal, filed in this Court on May 13, 2015; (5) begin work towards Brief for 

Appellant in Jose Lozano v. State, Appeal No. 05-14-00593-CR, with trial court 

findings due on June 17, 2015; and (6) Brief for Appellant in Humberto 

Martinez-Benitez v. State, Appeal No. 02-14-00440-CR, a 90-year sentence 

murder case, filed in the Second Court of Appeals of Texas on May 29, 2015.

III.

For the foregoing reasons, Appellant respectfully requests this Court to 

accept the brief that has been tendered and to order for it to be filed on any 

such terms as this Court would prescribe. TEX. R. APP. P. 10.1, 10.5, 38.6, 

38.8.
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Respectfully submitted,

/s/ Christian T. Souza

Christian T. Souza

SBN: 00785414

4303 N. Central Expressway

Dallas, Texas 75205

Tel. (214) 862-7462

Fax (214) 696-0867

ctsouza@gmail.com

Attorney for Appellant
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CERTIFICATE OF SERVICE

I certify serving a true and correct copy of this motion to Appellate 

Division, Dallas County District Attorney, 133 N. Riverfront Blvd., Dallas, 

Texas 75219, by regular mail, commercial delivery, or by delivery via 

electronic mail on May 31, 2015.

/s/ Christian T. Souza

Christian T. Souza