ACCEPTED 14-17-00130-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 12/19/2017 6:43 AM CHRISTOPHER PRINE CLERK

No. 14-17-00130-CR In the Court of Appeals FILED IN 14th COURT OF APPEALS For the HOUSTON, TEXAS Fourteenth District of Texas 12/19/2017 6:43:25 AM At Houston CHRISTOPHER A. PRINE  Clerk

No. 2118163 In County Criminal Court at Law No. 3 Of Harris County, Texas  AHMED SALAU 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. Appellant was charged by information with displaying an identification

certificate that was not issued to him. (CR – 10) Appellant was convicted by a

jury and sentenced by the trial court to 350 days in the Harris County Jail. (CR

– 97-98) Appellant timely filed notice of appeal and the trial court certified

appellant’s right of appeal. (CR – 127-29) 2. The State’s brief was due December 13, 2017. This Court has previously

granted three extensions of time for the State to file an appellate brief on

September 15, 2017, October 13, 2017, and November 13, 2017. The

undersigned attorney filed a motion requesting extension of time to file the

State’s appellate brief to Monday, December 18, 2017, which has not been

ruled upon by this Court. The following facts are relied upon to show good

cause for an extension of time to allow the State to file its brief:

a. The undersigned attorney has been involved in the following appellate projects during which time the undersigned attorney was assigned State’s appellate brief in this case:

1) Kenneth Hawkins v. State of Texas No. 01-16-00879-CR Brief Submitted: September 13, 2017

2) Andrew Kizer v. State of Texas No. 01-16-00937-CR Brief Submitted: September 30, 2017

3) Jesus Rosales v. State of Texas No. 14-16-00766-CR No. 14-16-00764-CR Brief Submitted: October 5, 2017 Submitted on Oral Argument: October 25, 2017 **State intends to submit a post-submission brief, which has required extensive research and has interfered with completion of the appellate brief in this case

4) Dylan Quick v. State of Texas No. 14-15-01066/0167/0168-CR Brief Submitted: October 30, 2017 *set for submission on oral argument: January 23, 2018 *State intends to submit a reply brief in this case

5) William Marks v. State of Texas PD – 0549/0550/0551-17 Brief on Discretionary Review Submitted: October 30, 2017

6) Jose Oliva v. State of Texas PD – 0398-17 Submitted on Oral Argument: November 1, 2017

7) State of Texas v. Carlos Mora Ex parte Carlos Mora No. 01-17-00661-CR No. 01-17-00662-CR Brief Submitted: November 7, 2017

8) Evan Gamble v. State of Texas No. 01-17-00405-CR Brief Due: December 27, 2017

9) James Tinsley v. State of Texas No. 01-17-00296-CR Brief Due: January 3, 2018

b. The undersigned attorney has had to conduct legal research for and assist with questions from trial prosecutors. The undersigned attorney has had to attend meetings and in-house training, and has also had to appear in court for work-related purposes. Such activity has interfered with the undersigned attorney’s ability to complete the appellate brief in this case. c. The undersigned attorney fell ill unexpectedly, which interfered significantly with the undersigned attorney’s ability to complete the State’s brief in this case. The undersigned attorney is beginning vacation leave on December 19, 2017, but is continuing to work diligently to complete and file the State’s appellate brief in this case.

WHEREFORE, the State prays that this Court will grant an extension of time, to

Wednesday, December 20, 2017, for the undersigned attorney to complete and file

the State’s appellate brief in this case.

Respectfully submitted,

/s/ Patricia McLean PATRICIA MCLEAN Assistant District Attorney Harris County, Texas [email protected] TBC No. 24081687

CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument will be served by e- filing to:

Scott Pope Attorney for Appellant [email protected]

/s/ Patricia McLean PATRICIA MCLEAN Assistant District Attorney Harris County, Texas [email protected] Date: December 19, 2017 TBC No.24081687