ACCEPTED 14-15-00104-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 11/17/2015 1:24:15 PM CHRISTOPHER PRINE CLERK No. 14-15-00104-CR In the Court of Appeals FILED IN 14th COURT OF APPEALS For the HOUSTON, TEXAS Fourteenth District of Texas 11/17/2015 1:24:15 PM At Houston CHRISTOPHER A. PRINE ♦ Clerk No. 1374647 In the 182nd District Court Of Harris County, Texas ♦ VICENTE EDDIE MATTA Appellant V. THE STATE OF TEXAS Appellee ♦ STATE’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF ♦ TO THE HONORABLE COURT OF APPEALS: THE STATE OF TEXAS, pursuant to TEX. R. APP. P. 2 & 10.5, moves for an extension of time in which to file its appellate brief and in its motion, would show the Court the following: 1. The appellant was charged with the capital murder of Al Dehghani committed on January 7, 2013 (CR – 23). He pled “not guilty” to the charge, and the case was tried to a jury (CR – 493). The jury found the appellant guilty and sentenced him to life in prison on January 26, 2015 (CR – 493). The appellant filed notice of appeal that same day, and the trial court certified his right to appeal (CR – 496, 514).

2. The State’s brief was due on November 13, 2015. The State hereby requests a 30-day extension for the filing of the State’s brief.

3. The following facts are relied upon to show good cause for an extension of time to allow the State to file its brief: a. This case was not assigned to the undersigned attorney until today, November 17, 2015. The notes in the file folder indicate that the State did not receive the appellant’s brief until November 16, 2015.

b. The undersigned attorney has researched and answered by email more than 50 legal questions of trial prosecutors since the appellant filed his brief. The undersigned attorney researched and answered even more such questions by phone during that time period.

c. The undersigned attorney has been involved in completing the following written appellate project since the appellant filed his brief: (1) Ana Gonzalez-Angulo v. The State of Texas No. 01-14-00886-CR Brief filed October 14, 2015 (2) Jonathan Young v. The State of Texas No. 14-15-00257-CR Brief filed October 15, 2015 (3) Raymond Eisenbach v. The State of Texas No. 14-15-00225-CR Brief filed October 16, 2015 (4) Marcus Brooks v. The State of Texas No. 14-14-00568-CR Brief filed November 2, 2015 (5) William Quinn v. The State of Texas No. 01-15-00116-CR Brief filed November 4, 2015 (6) Ex Parte Michael Sewell v. The State of Texas No. 14-15-00640-CR Brief filed November 12, 2015 WHEREFORE, the State prays that this Court will grant the requested extension.

Respectfully submitted, /s/ Eric Kugler ERIC KUGLER Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 (713) 755-5826 [email protected] TBC No. 796910 CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing instrument will be served by efile.txcourts.gov to: Kurt Wentz Attorney at Law 5629 Cypress Creek Pkwy, Suite 115 Houston, Texas 77069 [email protected] /s/ Eric Kugler ERIC KUGLER Assistant District Attorney Harris County, Texas 1201 Franklin, Suite 600 Houston, Texas 77002-1923 (713) 755-5826 TBC No. 796910 Date: November 17, 2015