Miko Deyond Parks v. State ( 2015 )

ACCEPTED
12-15-00043-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
5/8/2015 11:02:39 AM
CATHY LUSK
CLERK
NO. 12-15-00043-CR
FILED IN
12th COURT OF APPEALS
STATE OF TEXAS § IN THE TYLER, TEXAS
§ 5/8/2015 11:02:39 AM
VS. § TWELFTH COURT CATHY S. LUSK
§ Clerk
MIKO PARKS § OF APPEALS
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Miko Parks, Appellant in the above styled and numbered cause,
and moves this Court to grant an extension of time to file appellant's brief, pursuant
to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows
the following:
1. This case is on appeal from the 159th Judicial District Court of
Angelina County, Texas.
2. The case below was styled the STATE OF TEXAS vs. Miko Parks,
and numbered 2014-0129.
3. Appellant was convicted of Possession of Marijuana and Possession
of Controlled Substance.
4. Appellant was assessed a sentence of nine years eleven months
incarceration in the Texas Department of Criminal Justice Institutional Division on
January 30, 2015.
5. Notice of appeal was given on February 2, 2015.
6. The clerk's record was filed on March 31, 2015; the reporter's record
was filed on April 15, 2015.
7. The appellate brief is presently due on May 15, 2015.
8. Appellant requests an extension of time of 30 days from the present
date, i.e. June 15, 2015.
9. No previous extension to file the brief has been received in this cause.
10. Defendant is currently free on bond.
11. Appellant relies on the following facts as good cause for the requested
extension:
Counsel has a burgeoning practice. Counsel is preparing numerous felony
and misdemeanor cases in Angelina County, Nacogdoches County, Polk County,
Trinity County, San Jacinto County, Shelby County, and Cherokee County, Texas.
In addition, the Reporter’s Record in this case is very extensive and counsel needs
additional time to complete and file Appellant’s Brief.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this
Court grant this Motion To Extend Time to File Appellant's Brief, and for such
other and further relief as the Court may deem appropriate.
Respectfully submitted,
DEATON LAW FIRM
103 East Denman
Lufkin, TX 75901
Tel: (936) 637-7778
Fax: (936) 637-7784
By:
T. Ryan Deaton
State Bar No. 24007095
Attorney for Miko Parks
CERTIFICATE OF SERVICE
This is to certify that on May 8, 2015, a true and correct copy of the above
and foregoing document was served on the District Attorney's Office, Angelina
County, Texas, by fax.
T. Ryan Deaton