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 July 24, 2015. 

4. The State has not previously requested an extension of time to file its brief. 

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ACCEPTED

01-15-00032-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

7/24/2015 5:26:06 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/24/2015 5:26:06 PM CHRISTOPHER A. PRINE Clerk
5. The State hereby requests a 30-day extension of time to file its brief, until 

August 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 appellant brief in Ramon Aguilar, 

Jr. v. The State of Texas, Case No. 09-13-00573-CR, the State’s answer 

to application for writ of habeas corpus, and proposed findings of fact 

and conclusions of law in Ex parte Bruilo Rudio Mendoza, Case No. 

12-07-07741-CR-(1), the State’s answer to application for writ of 

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

Ex parte Kevin Arthur Larson, Case No. 12-10-11018-CR-(1), the 

State’s motion to forward the application for post-conviction writ of 

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

Ex parte Terry Wilkerson, Case No. 06-09-09388-CR-(1), the State’s 

answer to application for writ of habeas corpus, and proposed findings 

of fact and conclusions of law in Ex parte Thomas Lee Evans, Case No. 

19180-(1), the State’s proposed designation of issues in Ex parte Gene 

Buentello, Case No. 14-01-00113-CR-(1), the State’s proposed 

designation of issues in Ex parte Gabriel Silva, Case No. 

11-06-06274-CR-(1), and the State’s proposed designation of issues in 

Ex parte Willie D. Hubbard, Jr., Case No. 13-03-03070-CR-(1), and 

the State’s proposed designation of issues in Ex parte Michael Scott, 

Case No. 10-03-02964-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.

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Further, the undersigned counsel was out of the office from July 

14, 2015, through July 21, 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 

August 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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