ACCEPTED 14-14-00795-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 3/12/2015 8:57:02 AM CHRISTOPHER PRINE CLERK NO. 14-14-00795-CR IN THE COURT OF APPEALS FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS FOURTEENTH DISTRICT 3/12/2015 8:57:02 AM CHRISTOPHER A. PRINE Clerk HOUSTON, TEXAS

NO. 1396498 IN THE TRIAL COURT 182ND JUDICIAL DISTRICT HARRIS COUNTY, TEXAS

MICHALE LLOYD GATES § APPELLANT VS. § THE STATE OF TEXAS § APPELLEE

MOTION FOR EXTENSION OF TIME FOR FILING APPELLANT’S PRO SE BRIEF

ALLEN C. ISBELL Travis, Suite 208 Houston, Texas 77002 713/236-1000 Fax No. 713/236-1809 STATE BAR NO. 10431500 COUNSEL ON APPEAL TO THE HONORABLE COURT OF APPEALS: COMES NOW MICHAEL LLOYD GATES, appellant, by and through his counsel on appeal, ALLEN C. ISBELL, and respectfully requests that this Honorable Court grant an Extension of Time for Filing the Appellant’s Pro Se Brief. For cause would show the Court as follows: I.

On September 11, 2014, appellant was convicted of Aggravated Sexual Assault of a Child - Under 14, in the 182th District Court of Harris County, Texas entitled The State of Texas vs. MICHAEL LLOYD GATES, in Cause Number 1396498 was sentenced to seven (7) years confinement in the Texas Department of Criminal Justice, Institutional Division. No Motion for New Trial was filed. Written Notice of Appeal was given September 17, 2014.

II.

Counsel on appeal filed a Brief for Appellant on March 11, 2015, which was wholly frivolous.

Appellant has been advised of his right to examine a copy of the record and file a Pro Se Brief in his own behalf if he should so desire.

III.

This is the first (1) extension requested.

c:\appeal\gates\extension for pro se brief 2 IV.

Appellant’s last known address is as follows: Michael Lloyd Gates, SPN #01642871, 6/J/1, 701 N. San Jacinto, Houston, Texas 77002.

V. This motion is urged at the first opportunity as appellant is indigent and will suffer irremediable harm if it is not granted.

WHEREFORE, PREMISES CONSIDERED, appellant prays that this Honorable Court grant this extension of time in which to file the Appellant’s Pro Se Brief until May 11, 2015.

Respectfully submitted,

/s/ Allen C. Isbell ALLEN C. ISBELL Travis, Suite 208 Houston, Texas 77002 713/236-1000 Fax No. 713/236-1809 STATE BAR NO. 10431500 email: [email protected] COUNSEL ON APPEAL

c:\appeal\gates\extension for pro se brief 3 Certificate of Service I hereby certify that on this 11th day of March, 2015, a true and correct copy of the foregoing Motion for Extension of Time for Filing Appellant’s Pro Se Brief was sent to the District Attorney's Office, Appellate Division of Harris County, Texas, and to the Mr. Michael Lloyd Gates, appellant.

/s/ Allen C. Isbell ALLEN C. ISBELL

Certificate of Compliance The undersigned attorney on appeal certifies this motion is computer generated and consists of 454 words. Counsel is relying on the word count provided by the Word Perfect computer software used to prepare the motion.

/s/ Allen C. Isbell ALLEN C. ISBELL

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