                                                                                                   ACCEPTED
                                                                                               01-15-00325-CR
                                                                                    FIRST COURT OF APPEALS
                                                                                            HOUSTON, TEXAS
                                                                                        10/12/2015 12:43:19 PM
                                                                                         CHRISTOPHER PRINE
                                                                                                        CLERK

                       Nos. 01-15-00324-CR & 01-15-00325-CR

                                          In the                             FILED IN
                                    Court of Appeals                  1st COURT OF APPEALS
                                                                          HOUSTON, TEXAS
                                         For the                     10/12/2015 12:43:19 PM
                             First Judicial District of Texas         CHRISTOPHER A. PRINE
                                       At Houston                             Clerk


                              

                               Nos. 1296861 & 1297213
                             In the 248th District Court of
                                 Harris County, Texas

                              

                                ASTIN CHAVERS CLARK
                                       Appellant
                                         v.
                                 THE STATE OF TEXAS
                                       Appellee

                              

                 STATE’S MOTION FOR EXTENSION OF TIME
                    IN WHICH TO FILE APPELLATE BRIEF

                              

TO THE HONORABLE COURT OF APPEALS OF TEXAS:

       COMES NOW THE STATE OF TEXAS, in accordance with Rules 10.1(a)

and 38.6(d) of the Texas Rules of Appellate Procedure, and files this motion for

extension of time in which to file the State’s brief in this case, and, in support thereof,

presents the following:
1. In the 248th District Court of Harris County, Texas, in The State of Texas v.

   Astin Chavers Clark, Cause Numbers 1296861 and 1297213, appellee was

   charged with burglary.

2. Appellee pleaded guilty and was sentenced to twenty-five years incarceration.

3. The State’s brief was due on October 12, 2015.

5. A 30 day extension of time in which to file the State’s brief is requested until

   November 11, 2015.

6. Two previous extensions have been requested by the State.

7. The facts relied upon to explain the need for this extension are:

   a) Since assigned this case, the undersigned attorney has completed the State’s

      briefs in the following case:

      (1) Cause Number 14-14-00874-CR, Charles Roberts v. The State of Texas;

      (2) Cause Number 04-14-01010-CR, Marcus D. Jackson v. The State of Texas,;

      (3) Cause Number 14-14-01008-CR, Mary Kuol v. The State of Texas;

      (4) Cause Number 14-15-00405-CR, Jermaine Lewis v. The State of Texas;

      (5) Cause Number 14-14-00375-CR, Frank Distefano v. The State of Texas;

      (6) and Cause Number 14-15-00503-CR, The State of Texas v. Pastor Isreal

          Diaz-Bonilla.

   b) The undersigned attorney has also had to prepare for oral argument in

      Cause Number 14-14-00375-CR, Frank Distefano v. The State of Texas, which

      occurred on October 8, 2015 and is also preparing for oral argument in
          Cause Number 14-14-01008-CR, Mary Kuol v. The State of Texas, which will

          occur on October 22, 2015.

      c) The undersigned attorney is also currently engaged in the preparation of the

          State’s Brief in the following appellate cause numbers:

          (1) Cause Number 01-14-00885-CR, Abner Washington v. The State of Texas;

          (2) Cause Number 01-15-00533-CR, Rodney Burnett, Appellant v. The State of

             Texas, Appellee, which involves five points of error;

          (3) and Cause Number 14-15-00167-CR, Carl Dion Lovings v. The State of

             Texas.

WHEREFORE, the State prays that this Court will grant an extension of time until

November 11, 2015 in which to file the State’s brief in this case.

                                                      Respectfully submitted,

                                                      /s/                         Carly Dessauer
                                                      ________________________________________________________________________________________________________________________________________________________________________________________________________________________________




                                                      CARLY DESSAUER
                                                      Assistant District Attorney
                                                      Harris County, Texas
                                                      1201 Franklin, Suite 600
                                                      Houston, Texas 77002
                                                      (713) 755-5826
                                                      State Bar No. 24069083
                                                      dessauer_carly@dao.hctx.net
                         CERTIFICATE OF SERVICE

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

appellant’s attorney on October 12, 2015 through TexFile:


Allison Secrest
Attorney at Law
808 Travis Street, 24th Floor
Houston, Texas 77010
Allison@allisonsecrestlaw.com

                                                   /s/                          Carly Dessauer
                                                   ________________________________________________________________________________________________________________________________________________________________________________________________________________________________




                                                   CARLY DESSAUER
                                                   Assistant District Attorney
                                                   Harris County, Texas
                                                   1201 Franklin, Suite 600
                                                   Houston, Texas 77002
                                                   (713) 755-5826
                                                   State Bar No. 24069083
                                                   dessauer_carly@dao.hctx.net
                                                   curry_alan@dao.hctx.net
Date: October 12, 2015
