ACCEPTED 01-15-00325-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 10/12/2015 12:43:19 PM CHRISTOPHER PRINE CLERK Nos. 01-15-00324-CR & 01-15-00325-CR In the FILED IN Court of Appeals 1st COURT OF APPEALS HOUSTON, TEXAS For the 10/12/2015 12:43:19 PM First Judicial District of Texas CHRISTOPHER A. PRINE At Houston Clerk

 Nos. 1296861 & 1297213 In the 248th District Court of Harris County, Texas  ASTIN CHAVERS CLARK 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. Astin Chavers Clark, Cause Numbers 1296861 and 1297213, appellee was charged with burglary.

2. Appellee pleaded guilty and was sentenced to twenty-five years incarceration.

3. The State’s brief was due on October 12, 2015.

5. A 30 day extension of time in which to file the State’s brief is requested until November 11, 2015.

6. Two previous extensions have been requested by the State.

7. The facts relied upon to explain the need for this extension are: a) Since assigned this case, the undersigned attorney has completed the State’s briefs in the following case: (1) Cause Number 14-14-00874-CR, Charles Roberts v. The State of Texas; (2) Cause Number 04-14-01010-CR, Marcus D. Jackson v. The State of Texas,; (3) Cause Number 14-14-01008-CR, Mary Kuol v. The State of Texas; (4) Cause Number 14-15-00405-CR, Jermaine Lewis v. The State of Texas; (5) Cause Number 14-14-00375-CR, Frank Distefano v. The State of Texas; (6) and Cause Number 14-15-00503-CR, The State of Texas v. Pastor Isreal Diaz-Bonilla.

b) The undersigned attorney has also had to prepare for oral argument in Cause Number 14-14-00375-CR, Frank Distefano v. The State of Texas, which occurred on October 8, 2015 and is also preparing for oral argument in Cause Number 14-14-01008-CR, Mary Kuol v. The State of Texas, which will occur on October 22, 2015.

c) The undersigned attorney is also 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 01-15-00533-CR, Rodney Burnett, Appellant v. The State of Texas, Appellee, which involves five points of error; (3) and Cause Number 14-15-00167-CR, Carl Dion Lovings v. The State of Texas.

WHEREFORE, the State prays that this Court will grant an extension of time until November 11, 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 [email protected] CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument will be served to appellant’s attorney on October 12, 2015 through TexFile:

Allison Secrest Attorney at Law Travis Street, 24th Floor Houston, Texas 77010 [email protected] /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 [email protected] [email protected] Date: October 12, 2015