ACCEPTED 14-14-00761-cr FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 4/30/2015 4:04:30 PM CHRISTOPHER PRINE CLERK

No. 14-14-00761-CR No. 14-14-00762-CR FILED IN 14th COURT OF APPEALS In the HOUSTON, TEXAS Court of Appeals 4/30/2015 4:04:30 PM For the CHRISTOPHER A. PRINE Clerk Fourteenth District of Texas At Houston  Nos. 1417875 & 1417876 In the 338th Criminal District Court Of Harris County, Texas  ERIC MARTIN 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: THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 10.1, 10.5(b) & 38.6(d), moves for an extension of time within which to file its appellate brief. In support of its motion, the State submits the following: 1. Appellant was charged with two counts of sexual assault of a child.

2. Appellant entered a plea of “guilty” to both charges.

3. After a PSI hearing, appellant was sentenced to confinement for 15 years on each charge.

4. Appellant filed a written notice of appeal on August 24, 2014.

5. Appellant’s brief was filed March 18, 2015.

6. The State’s brief was due April 20, 2015.

7. The State seeks an extension until today, April 30, 2015, to file its brief.

8. The following facts are relied upon to show good cause for the requested extension: a. The undersigned attorney has filed 3 briefs in the last 30 days and has 5 more briefs due in the next 30 days.

b. In the last two months, the undersigned attorney has attended three funerals out of town, two of which were close family members. Additionally, the undersigned attorney took time off for a sick family pet that passed away a month ago.

c. The State’s motion is not for purposes of delay, but so that justice may be done.

WHEREFORE, the State prays that this Court will grant the requested extension until April 30, 2015.

Respectfully submitted, /s/ Bridget Holloway BRIDGET HOLLOWAY Assistant District Attorney Harris County, Texas Harris County Criminal Justice Center 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 Texas Bar No. 24025227 [email protected] CERTIFICATE OF SERVICE This certifies the undersigned attorney requested that a copy of this document be served to appellant’s attorneys via TexFile at the following email on April 30, 2015:

Marcus J. Fleming Attorney at Law Email: [email protected]

/s/ Bridget Holloway BRIDGET HOLLOWAY Assistant District Attorney Harris County, Texas Harris County Criminal Justice Center 1201 Franklin, Suite 600 Houston, Texas 77002 (713) 755-5826 Texas Bar No. 24025227 [email protected]