                                                                                                  ACCEPTED
                                                                                              14-15-00503-CR
                                                                              FOURTEENTH COURT OF APPEALS
                                                                                           HOUSTON, TEXAS
                                                                                         8/31/2015 3:11:51 PM
                                                                                        CHRISTOPHER PRINE
                                                                                                       CLERK

                                  No. 14-15-00503-CR

                                         In the                             FILED IN
                                   Court of Appeals                  14th COURT OF APPEALS
                                                                        HOUSTON, TEXAS
                                        For the                      8/31/2015 3:11:51 PM
                          Fourteenth Judicial District of Texas      CHRISTOPHER A. PRINE
                                      At Houston                              Clerk


                              

                                      No. 1311548
                             In the 208th District Court of
                                 Harris County, Texas

                              

                                THE STATE OF TEXAS
                                      Appellant
                                        v.
                            PASTOR ISREAL DIAZ-BONILLA
                                      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 208th District Court of Harris County, Texas, in The State of Texas v.

   Pastor Isreal Diaz-Bonilla, Cause Number 1311548, appellee was charged with

   engaging in organized criminal activity.

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

   However, the trial court granted appellee’s motion for new trial.

3. The State filed a timely notice of appeal.

4. The State’s brief was due on August 31, 2015.

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

   September 8, 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) The undersigned attorney has been unable to finish writing the State’s brief

      in this case since the last requested extension of time was granted by this

      Court.

   b) The undersigned attorney has finished writing the State’s briefs in the

      following case since being assigned to this case:

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

          Texas, Appellee, filed on July 9, 2015;

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

          of Texas, Appellee, filed on July 29, 2015;
          (3) Cause Number 14-14-01008-CR, Mary Kuol, Appellant, v. The State of

              Texas, Appellee, filed on July 30, 2015; and

          (4) and Cause Number 14-15-00405-CR, Jermaine Lewis, Appellant, v. The State

              of Texas, Appellee.

       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, Appellant v. The State

              of Texas, Appellee;

          (2) Cause Number 14-14-00375-CR, Frank Distefano, Appellant, v. The State of

              Texas, Appellee; and

          (3) Cause Numbers 01-15-00324-CR and 01-15-00325-CR, Astin Chavers

              Clark, Appellant, v. The State of Texas, Appellee.

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

September 8, 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 August 31, 2015 through TexFile:


Randy Schaffer
Attorney at Law
1301 McKinney, Suite 3100
Houston, Texas 77010
noguilt@swbell.net

                                                    /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: August 31, 2015
