                                                                                                   ACCEPTED
                                                                                               01-14-00900-cr
                                                                                    FIRST COURT OF APPEALS
                                                                                            HOUSTON, TEXAS
                                                                                        4/13/2015 12:32:12 PM
                                                                                          CHRISTOPHER PRINE
                                                                                                       CLERK

                                  No. 01-14-00900-CR

                                          In the                            FILED IN
                                    Court of Appeals                 1st COURT OF APPEALS
                                                                         HOUSTON, TEXAS
                                         For the                     4/13/2015 12:32:12 PM
                             First Judicial District of Texas        CHRISTOPHER A. PRINE
                                       At Houston                             Clerk


                              ♦

                                     No. 1344231
                             In the 180th District Court of
                                 Harris County, Texas

                              ♦

                                  FELICITY BURRIS
                                      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 180th District Court of Harris County, Texas, in The State of Texas v.

   Felicity Burris, Cause Numbers 1344231, appellant was charged with arson.

2. The court deferred appellant’s adjudication for five years.

3. The State’s brief is due on April 13, 2015.

5. An extension of time in which to file the State’s brief is requested until May 13,

   2015.

6. No previous extension has been requested by the State.

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

   a) The undersigned attorney was assigned this case on March 17, 2015.

   b) Since the undersigned attorney was assigned this case, the attorney finished

      writing the State’s briefs in the following cases:

      (1) Cause Number 14-14-00473-CR, Jimmy Earl Van-Cleave, Appellant v. The

           State of Texas, Appellee, which involves three points of error and three

           volumes of the reporter’s record;

      (2) Cause Number 01-14-00581-CR, Brodies E. Myles, Appellant v. The State of

           Texas, Appellee, which involves one points of error and four volumes of

           the reporter’s record; and

      (3) Cause Number 01-14-00421-CR, Eric Dewayne Small, Appellant v. The State

           of Texas, Appellee, which involves six points of error and eight volumes of

           the reporter’s record.
       c) The undersigned attorney was also preparing for oral argument in Cause

          Number 01-13-00931-CR, Melissa Dromgoole, Appellant v. The State of Texas,

          Appellee, that was held on April 8, 2015.

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

          State’s Brief in the following appellate cause numbers:

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

              Texas, Appellee, which involves three points of error and seven volumes

              of the reporter’s record;

          (2) Cause Number 01-14-00900-CR, James Lee Skinner, Appellant v. The State

              of Texas, Appellee, which involves three points of error and four volumes

              of the reporter’s record; and

          (3) Cause Number 14-14-00910-CR, Ex parte Erik Montes De Oca-Orozco,

              which involves two points of error and one volume of the reporter’s

              record.

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

May 13, 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 April 13, 2015 through TexFile:


Tommy LaFon
Attorney at Law
1244 Heights Blvd.
Houston, Texas 77008
tomlafon@aol.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: April 13, 2015
