Joseph Christopher Lewis v. State ( 2017 )


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  •                                                                                                            ACCEPTED
    09-17-00060-CR
    NINTH COURT OF APPEALS
    BEAUMONT, TEXAS
    12/13/2017 5:05 PM
    CAROL ANNE HARLEY
    CLERK
    NO:09-17-00060-CR
    TRIAL COURT CASE NO(s) 12519
    FILED IN
    COURT OF APPEALS                    9th COURT OF APPEALS
    NINTH DISTRICT                         BEAUMONT, TEXAS
    BEAUMONT, TEXAS                     12/13/2017 5:05:13 PM
    CAROL ANNE HARLEY
    JOSEPH LEWIS                                    §        APPEAL FROM               Clerk
    THE 1-A DISTRICT
    §        COURT
    §
    vs.                                             §        OF
    §
    THE STATE OF TEXAS, APPELLEE                    §        TYLER COUNTY, TEXAS
    MOTION TO EXTEND THE TIME
    FOR FILING APPELLANT’S BRIEF
    TO THE HONORABLE COURT OF APPEALS:
    COMES NOW the Appellant and moves the Court for an extension of time to file a
    Appellant’s brief in the cause, and in support thereof would show the Court as follows:
    I.
    On January 9th , 2009, the Appellant plead Guilty, to the offense of Aggravated Sexual
    Assault of a Child. On February 9th, 2017, he was found guilty by jury verdict, and was sentenced
    on February 9th, 2017, to a Life sentence in the Texas Department of Criminal Justice, under Cause
    No. 12,519; THE STATE OF TEXAS VS. JOSEPH CHRISTOPHER LEWIS; IN THE 1-a
    DISTRICT COURT OF TYLER COUNTY, TEXAS. THE STATE OF TEXAS VS. JOSEPH
    LEWIS; IN THE 1-A DISTRICT COURT OF TYLER, TEXAS.
    II.
    The Appellant timely filed his Notice of Appeal and the Transcript and Statement of Facts
    were timely filed herein, and the Appellant’s Brief was due to be filed herein on December 13th,
    2017.                                               III.
    Appellant respectfully requests that this Honorable Court grant an additional extension of
    approximately thirty (30) days or until January 12th, 2018, in filing Appellant’s Brief
    IV.
    The such extension is necessary for the following reasons:
    1.    Counsel makes this request for extension because he has been scheduled in multiple
    counties on the felony trial dockets in Jefferson, Hardin, Liberty, Newton, and Tyler Counties, for
    announcement, pretrial and trial dockets. Counsel has been heavily scheduled on the Hardin County
    Dockets, in both the 356th and 88th Judicial District Courts. Counsel sincerely apologizes to this
    honorable court for filing an additional extension and wishes to remain in good standing with this
    Honorable Court, but he prays that the court will grant this second extension to allow the needed
    time to finalize and file Appellant’s Brief to ensure accuracy and eliminate the possibility of error.
    2.     As well, counsel respectfully informs the court he has been working on several other
    briefs, (in the Ninth Court of Appeals), writs and petitions for discretionary review, during this time
    of which have required more than the usual amount of time in research and reviewing case law.
    3.    Counsel informs the court this extension is not sought for delay, but that justice may
    be done.
    WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests and prays
    that this Honorable Court extend the time for the filing of Appellant’s Brief herein approximately
    on January 12th, 2018.
    Respectfully submitted,
    /s/ Bryan S. Laine
    Bryan S. Laine
    TBN. #24011488
    1045 S. Redwood
    Kountze, Texas 77625
    Tel: (409) 246-4008
    Fax: (409) 246-3645
    bryanlaine@gt.rr.com
    CERTIFICATE OF SERVICE
    I hereby certify that true and correct copy of the foregoing document has been forwarded
    to all opposing counsel and parties on this the 13th day of December 2017.
    By:/s/ Bryan S.Laine
    /s/Bryan S. Laine
    State Bar No. 24011488
    NO:09-17-00060-CR
    TRIAL COURT CASE NO(s) 12,519
    COURT OF APPEALS
    NINTH DISTRICT
    BEAUMONT, TEXAS
    JOSEPH LEWIS                                   §    APPEAL FROM THE 1-A DISTRICT
    §    COURT
    §
    vs.                                            §    OF
    §
    THE STATE OF TEXAS, APPELLEE                   §    HARDIN COUNTY, TEXAS
    ORDER
    On________________________, 2017, came on to be considered JOSEPH LEWIS’S
    Appellant’S Motion to Extend the Time For Filing Appellant’s Brief and said motion is hereby:
    (Granted)       (Denied)
    JUDGE PRESIDING
    

Document Info

Docket Number: 09-17-00060-CR

Filed Date: 12/13/2017

Precedential Status: Precedential

Modified Date: 12/15/2017