Wade Allen Laurence v. State ( 2015 )

ACCEPTED
08-15-00114-CR
08-15-00114-CR EIGHTH COURT OF APPEALS
EL PASO, TEXAS
11/4/2015 9:55:44 AM
DENISE PACHECO
CLERK
IN THE COURT OF APPEALS
EIGHTH DISTRICT OF TEXAS 8th COURT
FILED IN
OF APPEALS
EL PASO, TEXAS
AT FORT WORTH 11/4/2015 9:55:44 AM
DENISE PACHECO
Clerk
THE STATE OF TEXAS § COA NO 08-15-00114-CR
§
V §
§
WADE ALLEN LAURENCE § TRIAL COURT NO F46727
MOTION TO EXTEND TIME
TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Wade Allen Laurence, 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 18th Judicial District Court,
Johnson County, Texas; the Honorable John Neill presiding.
2. The case herein was styled The State of Texas v. Wade Allen
Laurence and numbered F46727.
3. Appellant was charged with the felony offense of obtaining a
Laurence, Wade Allen
Motion to Extend Time To File Appellant’s Brief page - 1 -
controlled substance by fraud.
4. Appellant was found guilty as charged and received a
probated sentence of seven (7) years and assessed a fine in the amount of
$4,000.
5. Motion for New Trial was filed with the Clerk March 16,
2015.
6. Notice of Appeal was filed with the Clerk March 23, 2015.
7. Appellant remains at liberty on an appeal bond at this time.
8. The reporter’s record was filed July 29, 2015; the clerk’s
record was filed March 24, 2015.
8. Appellant’s brief was due to be filed by September 27, 2015.
9. Appellant requests an extension of time of thirty days from
the original due date, i.e. November 27, 2015.
10. This is the third request for an extension of time to file
Appellant’s brief in this cause.
11. Appellant relies on the following facts as good cause for the
requested extension:
Due to ongoing health issues and continued day to day treatment,
two days of assessments and treatment at MD Anderson in October, as
Laurence, Wade Allen
Motion to Extend Time To File Appellant’s Brief page - 2 -
well as being involved in numerous trials, court appearances, and court
proceedings in Tarrant, Parker, Wise, and Johnson counties during the
last thirty days, Counsel requires additional time to review his trial
notes and complete the Appellant’s brief for filing herein.
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,
/s/ Jim Shaw
JIM SHAW
LAW OFFICE OF JIM SHAW
916 W. Belknap Street
Fort Worth, Texas 76l02
(8l7) 877-040l Fax (817) 877-0404
jimshaw@jimshawlaw.com
ATTORNEYS FOR APPELLANT
Laurence, Wade Allen
Motion to Extend Time To File Appellant’s Brief page - 3 -
CERTIFICATE OF CONFERENCE
This is to certify that personnel in my office have spoken with
personnel in the Johnson County District Attorney’s office and was
advised that their office does not oppose the filing of this motion.
/s/ Jim Shaw
JIM SHAW
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing has
been e-served to David Vernon, Assistant District Attorney, Johnson
County District Attorney at davidv@johnsoncountytx.org on this 4th day
of November, 2015.
/s/ Jim Shaw
JIM SHAW
ORDER
On this the day of , 2015, came to be
heard Appellant’s Motion To Extend Time To File Appellant’s Brief,
and it appears to the Court that this motion should be [granted /
denied].
IT IS THEREFORE ORDERED that the time for filing
Appellant’s brief in this cause be extended to the 27th day of November,
2015.
JUDGE PRESIDING
Laurence, Wade Allen
Motion to Extend Time To File Appellant’s Brief page - 4 -