                                                                                                   ACCEPTED
                                                                                               01-14-00885-CR
                                                                                    FIRST COURT OF APPEALS
                                                                                            HOUSTON, TEXAS
                                                                                          6/10/2015 1:33:10 PM
                                                                                         CHRISTOPHER PRINE
                                                                                                        CLERK

                                  No. 01-14-00885-CR

                                          In the                            FILED IN
                                    Court of Appeals                 1st COURT OF APPEALS
                                                                         HOUSTON, TEXAS
                                         For the                     6/10/2015 1:33:10 PM
                             First Judicial District of Texas        CHRISTOPHER A. PRINE
                                       At Houston                            Clerk


                              ⎯⎯⎯⎯⎯♦⎯⎯⎯⎯⎯

                                     No. 1430059
                             In the 248th District Court of
                                 Harris County, Texas

                              ⎯⎯⎯⎯⎯♦⎯⎯⎯⎯⎯

                               ABNER L. WASHINGTON
                                     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.

   Abner L. Washington, Cause Number 1430059, appellant was convicted of

   possession of a controlled substance.

2. Appellant was sentenced to sixty days incarceration in the Harris County Jail.

3. The State’s brief was due on June 10, 2015.

5. An extension of time in which to file the State’s brief is requested until July 10,

   2015.

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 March 22, 2014;

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

      writing the State’s briefs in the following cases:

      (1) Cause Number 01-14-00900-CR, Felicity Burris, Appellant v. The State of

           Texas, Appellee, which involved one point of error and two volumes of

           the reporter’s record and is due on May 13, 2015; and

      (2) Cause Number 01-14-00748-CR, James Lee Skinner, Appellant v. The State

           of Texas, Appellee, which involved three points of error and is due on May

           18, 2015.

   c) The undersigned attorney has also been assigned to engaged in the

      preparation of the State’s Brief in the following appellate cause numbers
          (1) Cause Number 01-14-00772-CR, Thanh Hoang, Appellant v. The State of

              Texas, Appellee, which involves one point of error; and

          (2) 14-14-00874-CR, Charles Roberts, Appellant v. The State of Texas, Appellee,

              which involves three points of error.

       d) Additionally, the undersigned attorney has also been out of the office last

          week from the flooding in Houston and from attending the Conference on

          Criminal Appeals in Austin.

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

July 10, 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 June 10, 2015 through TexFile:


Sarah V. Wood
Assistant Public Defender, Harris County
1201 Franklin Street, 13th Floor
Houston, Texas 77002
sarah.wood@pdo.hctx.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: June 10, 2015
