ACCEPTED 14-15-00372-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 10/22/2015 2:06:49 PM CHRISTOPHER PRINE CLERK IN THE FOURTEENTH COURT OF APPEALS OF TEXAS FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS BO DANIEL SHAFER § CASE NO. 10/22/2015 14-15-00372CR 2:06:49 PM § CHRISTOPHER A. PRINE § Clerk VS. § On Appeal From Harris County § Cause No. 1433928 § 184TH District Court THE STATE OF TEXAS § APPELLANT’S MOTION TO EXTEND TIME TO FILE APPELLATE BRIEF Appellant, Bo Daniel Shafer, moves for an extension of time to file his appellate brief, under TEX. R. APP. P. 10.5(b).

I. TRIAL COURT PROCEEDINGS On March 18, 2015, the trial court entered judgment against Mr. Shafer after a jury found him guilty of continuous sex abuse of a child and assessed punishment at 26 years in the Institutional Division -- TDCJ. Mr. Shafer filed a notice of appeal on March 18, 2015.

II. PROCEEDINGS IN THIS COURT The Appellant’s brief is due October 22, 2015. Previous extension have been requested.

III.

Since the previous extension, counsel has been working to complete a brief in Margaret Mayer v. State, Cause No. 14-14-01011-CR, which has been abated; and in Kendall Bell v. State, Cause No. 01-15-00510-CR; Vincent Broussard v. State, Cause No. 14- 15-00526-CR. Counsel also is finishing a petition for discretionary review in Reginald Hill v. State, Cause No. 14-14-00376-CR, which has no further extensions. In this same 30-day period, counsel has researched and prepared a response to the state’s motion for the juvenile court to waive jurisdiction after a reversal and remand on appeal in Jorge Guerrero v. State, Cause No. 14-13-00101-CR, for a hearing that ultimately was reset.

IV.

In the exercise of due diligence, counsel was unable to complete the brief by the deadline, and needs an additional 30 days to file it. This motion is not filed for purposes of delay, but so that justice may be done.

PRAYER Appellant respectfully requests that this motion be granted and that the Court permit an extension of time until November 23, 2015 to file Appellant’s brief.

Respectfully submitted, ALEXANDER BUNIN Chief Public Defender Harris County Texas

/s/ Cheri Duncan ______________________________ CHERI DUNCAN Assistant Public Defender Harris County Texas SBN 06210500 1201 Franklin, 13th Floor Houston Texas 77002 (713) 368-0016 (713) 368-9278 (Fax) [email protected] Attorney for Appellant, BO DANIEL SHAFER

CERTIFICATE OF SERVICE I certify that a copy of Appellant’s Motion to Extend Time to File Appellate Brief was served electronically on the Appellate Division of the Harris County District Attorney’s Office, 1201 Franklin St, 6th Floor, Houston, TX on October 22, 2015.

/s/ Cheri Duncan ____________________________________ CHERI DUNCAN