CAUSE NO. 01-15-00032-CR

CAUSE NO. 01-15-00033-CR

JOE EDDIE ALEJANDRO § IN THE COURT OF APPEALS FOR

§

V. § THE FIRST JUDICIAL DISTRICT,

§

THE STATE OF TEXAS § AT HOUSTON, TEXAS

____________________________________________________

STATE’S MOTION FOR 

EXTENSION OF TIME TO FILE BRIEF

____________________________________________________

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW the State of Texas, by the undersigned assistant district 

attorney, and moves the Court for an extension of time to file its appellate brief in the 

above-captioned cases. The State would respectfully show the Court the following: 

1. On November 6, 2014, the appellant was convicted of the offense of

aggravated sexual assault of a child (Ct. II), and indecency with a child by sexual 

contact (Ct. III), and his punishment was assessed in Count II at imprisonment for 

thirty years, and in Count III at imprisonment for ten years. 

2. The appellant’s brief was filed in this Court on June 24, 2015. 

3. The State’s brief is presently due to be filed in this Court on August 24, 

2015. 

4. The State has previously requested one extension of time to file its brief. 

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ACCEPTED

01-15-00032-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

9/14/2015 11:09:38 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 9/14/2015 11:09:38 AM CHRISTOPHER A. PRINE Clerk
5. The State hereby requests a 30-day extension of time to file its brief, until 

September 24, 2015.

6. Good cause exists for the requested extension of time, for the following 

reasons:

In the past 30 days, the undersigned counsel for the State has 

been required to prepare the State’s petition for discretionary review in 

The State of Texas v. Jessica Sekerka Siegel, Case No. PD-0962-15, the 

State’s appellant brief in Jennifer Sobel v. The State of Texas, Case No. 

09-14-00426-CR,the State’s appellant brief in Gary Edward Vines v. 

The State of Texas, Case No. 09-14-00487-CR, the State’s appellant 

brief in Carol Ann Davis v. The State of Texas, Case No. 

09-15-00063-CR, the State’s answer to application for post-conviction 

writ of habeas corpus, and proposed findings of fact and conclusions of 

law in Ex parte Clyde James Freeman, Case No. 09-11-11188-CR-(3); 

the State’s answer to application for post-conviction writ of habeas 

corpus, and proposed findings of fact and conclusions of law in Ex 

parte Steven Keith Milliff, Case No. 11-03-02327-CR-(1). 

In addition, undersigned counsel is assigned to serve as the 

prosecutor on Montgomery County’s misdemeanor expunction and 

nondisclosure cases, and has been required to attend to numerous 

hearings and other duties pursuant to those assignments, and is also 

assigned to serve as the prosecutor on Montgomery County’s mental 

health cases, and has been required to attend to duties pursuant to that 

assignment

Further, the undersigned counsel was out of the office from 

August 5, 2015, through August 7, 2015, on a pre-planned vacation.

Consequently, counsel has not had sufficient time to prepare an 

adequate State’s brief in this case.

THEREFORE, the State requests an extension of time to file its brief until 

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September 24, 2015, in this case. 

Respectfully submitted,

BRETT W. LIGON

District Attorney

Montgomery County, Texas 

/s/ Jason Larman 

JASON LARMAN

Assistant District Attorney

Montgomery County, Texas

S.B.T. No. 24072468

207 W. Phillips, Second Floor

Conroe, Texas 77301

(936) 539-7800

(936) 788-8395 (fax)

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing motion was 

e-mailed to Ms. Heather Hall, attorney for the appellant on the date of the filing of 

the original with the Clerk of this Court.

/s/ Jason Larman 

JASON LARMAN

Assistant District Attorney

Montgomery County, Texas

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