IN THE COURT OF APPEALS FOR THE 

FIRST COURT OF APPEALS DISTRICT 

No. 01-13-000227-CR

JEREMY WASHINGTON 

Appellant, 

 On Appeal From the 8th 

V. County Court at Law 

Trial Cause Number 1862655

THE STATE OF TEXAS 

Appellee 

APPELLANT'S FINAL MOTION TO EXTEND TIME TO FILE BRIEF 

TO THE HONORABLE JUSTICES OF SAID COURT: 

 Jeremy Washington, Appellant in the above cause, would respectfully request that the 

Court grant his motion to extend the time to file his brief. In support of said motion, 

Appellant would show unto the Court the following: 

I.

 This appeal lies from Appellant's conviction in The State of Texas v. Jeremy Washington, 

cause number 1862655 in the 2nd County Criminal Court at Law of Harris County, Texas. 

The Appellant was charged by information with unlawful carrying of a weapon on 

November 16, 2012. The Appellant was found guilty on February 20, 2013, following a jury 

trial. The Appellant was sentenced to one (1) year confinement in the county jail, with his 

sentence suspended for a period of two (2) years of community supervision. Two previous 

extensions have been requested and granted. The Appellant’s completed brief is being 

submitted simultaneously along with this motion. 

ACCEPTED

01-13-00227-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

7/13/2015 12:54:22 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/13/2015 12:54:22 PM CHRISTOPHER A. PRINE Clerk
II.

The present case is one of a handful of cases that have been subject to an ongoing 

series of abatement hearings on the issue of whether the court reporter at trial, Sondra 

Humphrey, could produce a complete Reporter’s Record. On February 17, 2015, the State 

and the Appellant filed a Joint Motion to Reinstate Appeal in the wake of the conclusion of 

these hearings. On March 17, 2015, this Court issued an order reinstating the appeal.

III.

Appellant's attorney of record has not been able to timely file the brief for the 

following reasons:

1. A brief on the merits before the Court of Criminal Appeals in Jose 

Vasquez v. State of Texas, cause number 1333231, which was submitted 

on June 26, 2015;

2. Investigation for a potential Motion for New Trial in Michael Davila v. 

State of Texas, cause number 1359876, which would be due on July 18, 

2015;

3. A direct appeal brief in Weylin Alford v. State of Texas, cause number 

1450840, which is due on July 22, 2015;

4. A direct appeal brief in Kenneth Brown v. State of Texas, cause number 

1389982, which is due on August 5, 2015.
IV.

An extension of time is necessary so that the brief can be timely filed. This motion is 

not made for the purpose of delay. The Appellant’s completed brief is being filed 

simultaneously with this motion.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Honorable 

Court will grant this requested extension of time to file the Appellant's Brief in the above 

cause and extend the time for filing the brief to today, July 13, 2015.

Respectfully submitted,

Alexander Bunin

Chief Public Defender

/s Mark Kratovil______________

Mark Kratovil

State Bar No. 24076098

Harris County Public Defender’s Office

Assistant Public Defender

1201 Franklin, 13th Floor

Houston, Texas 77002

Tel: (713)274-6728

e-Fax: (713)437-4339
CERTIFICATE OF SERVICE

I certify that on July 13, 2015, a copy of the foregoing instrument has been served 

upon the State of Texas by electronic delivery via Texas eFile to the Appellate Division of 

the Harris County District Attorney’s Office.

/s Mark Kratovil

MARK KRATOVIL