                                                                                                   ACCEPTED
                                                                                               01-15-00274-CR
                                                                                    FIRST COURT OF APPEALS
                                                                                            HOUSTON, TEXAS
                                                                                        12/14/2015 10:23:31 AM
                                                                                         CHRISTOPHER PRINE
                                                                                                        CLERK

                                  No.01-15-00274-CR

                                          In the                             FILED IN
                                    Court of Appeals                  1st COURT OF APPEALS
                                                                          HOUSTON, TEXAS
                                         For the                     12/14/2015 10:23:31 AM
                             First Judicial District of Texas         CHRISTOPHER A. PRINE
                                       At Houston                             Clerk


                              

                                     No. 1428697
                             In the 184th District Court of
                                 Harris County, Texas

                              

                                ERIC SAMUEL TUCKER
                                      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 184th District Court of Harris County, Texas, in The State of Texas v.

   Eric Samuel Tucker, Cause Number 1428697, appellant was charged with

   aggravated assault.

2. Appellant was sentenced to incarceration for thirty years.

3. The State’s brief was due on December 14, 2015.

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

   13, 2016.

6. One 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 October 22, 2015.

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

      brief in the following cases:

      i) Cause number 01-15-00533-CR, Rodney Burnett v. The State of Texas;

      ii) Cause numbers 01-15-00324-CR and 01-15-00325-CR, Astin Chavers

          Clark v. The State of Texas;

      iii) Cause Number 14-15-00595-CR, Ricardo Martinez v. The State of Texas;

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

          Texas.

   c) The undersigned attorney is 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 01-15-00421-CR, Albert Lynch v. The State of Texas;

          (3) Cause Number 01-14-00493-CR, Luis Ruiz Sierra v. The State of Texas;

          (4) and Cause Number 01-15-00290-CR, Ferdando Razo v. The State of Texas.

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

January 13, 2016 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) 274-5826
                                                        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 December 14, 2015 through TexFile:


Cheri Duncan
Assistant Public Defender
1201 Franklin, 13th Floor
Houston, Texas 77002
cheri.duncan@pdo.hctx.net



                                                   /s/                          Carly Dessauer
                                                   ________________________________________________________________________________________________________________________________________________________________________________________________________________________________




                                                   CARLY DESSAUER
                                                   Assistant District Attorney
                                                   Harris County, Texas
                                                   1201 Franklin, Suite 600
                                                   Houston, Texas 77002
                                                   (713) 274-5826
                                                   State Bar No. 24069083
                                                   dessauer_carly@dao.hctx.net
                                                   curry_alan@dao.hctx.net
Date: December 14, 2015
