No. 14-14-00701-CR

In the 

Court of Appeals 

For the 

Fourteenth District of Texas 

At Houston 



No. 1397962

In the 177th District Court 

Of Harris County, Texas 



FRELIN DANILO ORELLANO 

Appellant 

V.

THE STATE OF TEXAS

Appellee



STATE’S MOTION FOR FINAL EXTENSION OF TIME TO FILE BRIEF 



TO THE HONORABLE COURT OF APPEALS: 

 THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 2 & 10.5, moves for 

an extension of time in which to file its appellate brief and in its motion, would 

show the Court the following: 

1. The appellant was charged with the aggravated robbery of Maria Estrada 

committed on August 13, 2013 (CR – 15). He pled “not guilty” to the 

charge, and the case was tried to a jury (CR – 183). The jury found the 

appellant guilty and sentenced him to 20 years in prison on August 22, 

2014 (CR – 183). The appellant filed notice of appeal three days later, 

and the trial court certified his right to appeal (CR – 186-188). 

ACCEPTED

14-14-00701-CR

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

7/14/2015 1:52:06 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 7/14/2015 1:52:06 PM CHRISTOPHER A. PRINE Clerk
2. The State’s brief was originally due on May 15, 2015, but this Court 

granted extensions until July 15, 2015. The State hereby requests a final 

30-day extension for the filing of the State’s brief. 

3. The following facts are relied upon to show good cause for an extension

of time to allow the State to file its brief:

a. The record in this case is over eighteen megabytes in length split 

over seven volumes and will take some time to process.

b. The undersigned attorney researched and answered by email more 

than 100 legal questions of trial prosecutors since the appellant 

filed his brief. The undersigned attorney researched and answered 

even more such questions by phone during that time period. 

c. The undersigned attorney is responsible for supervising six other 

appellate prosecutors, and has spent a substantial amount of time 

reviewing the briefs of those prosecutors, attending their oral 

arguments, and assisting in the preparation of both during that time 

period. The undersigned attorney has also been responsible for 

training two new appellate prosecutors, which requires more 

intense supervision and editing, and therefore, more of a time 

commitment.

d. The undersigned attorney has been involved in completing the 

following written appellate project since the appellant filed his

brief:

(1) Elder Somoza v. The State of Texas 

No. 01-14-00716-CR

Brief filed April 15, 2015

(2) In the Interest of B.D.S. v. The State of Texas 

No. 01-14-00762-CV

Brief filed April 28, 2015
(3) Jose Vasquez v. The State of Texas 

No. PD-0078-15

Brief on PDR filed May 12, 2015

(4) Antonio Perez v. The State of Texas 

No. 01-12-01001-CR

PDR filed May 12, 2015

(5) Johnathan Castaneda v. The State of Texas 

No. 01-14-00389-CR

No. 01-14-00390-CR

Brief filed May 18, 2015

(6) Griselda Aza v. The State of Texas 

No. 14-14-00241-CR

No. 14-14-00242-CR

Brief filed June 22, 2015

(7) Albert Febus v. The State of Texas 

No. 01-14-00942-CR

Brief filed June 24, 2015

(8) Richard Contreras v. The State of Texas 

No. 01-14-00758-CR

Brief filed July 7, 2015

WHEREFORE, the State prays that this Court will grant the requested extension.

Respectfully submitted,

/s/ Eric Kugler

ERIC KUGLER

Assistant District Attorney

Harris County, Texas

1201 Franklin, Suite 600

Houston, Texas 77002-1923

(713) 755-5826

Kugler_eric@dao.hctx.net

TBC No. 796910
CERTIFICATE OF SERVICE 

This is to certify that a copy of the foregoing instrument will be served by 

efile.txcourts.gov to:

Sarah Wood

Assistant Public Defender

Harris County, Texas

1201 Franklin, 13th Floor

Houston, Texas 77002

Sarah.wood@pdo.hctx.net

/s/ Eric Kugler

ERIC KUGLER

Assistant District Attorney

Harris County, Texas

1201 Franklin, Suite 600

Houston, Texas 77002-1923

(713) 755-5826

TBC No. 796910

Date: July 15, 2015