Dennis Lynch v. State ( 2015 )

ACCEPTED
12-14-00328-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
6/22/2015 3:41:35 PM
CATHY LUSK
CLERK
No. 12-14-00328-CR
DENNIS LYNCH § IN THE COURT OF APPEALS
FILED IN
Appellant § 12th COURT OF APPEALS
TYLER, TEXAS
§
vs. § 12TH JUDICIAL 6/22/2015
DISTRICT 3:41:35 PM
CATHY S. LUSK
§ Clerk
THE STATE OF TEXAS, §
Appellee § AT TYLER, TEXAS
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF
PENDING COURT’S DISMISSAL OF APPEAL
TO THE HONORABLE COURT:
Now comes Austin Reeve Jackson, counsel for Appellant in the above entitled and
numbered cause, and makes this Motion, and for good cause shows the following:
I.
Appellant’s brief in this matter is due on 25 June 2015. No prior extensions have
been requested.
II.
Counsel has filed a memorandum with the Court outlining that Mr. Lynch waived
his right to appeal at the time he entered his plea in this case. Additionally, the trial court
has filed findings of fact with the Court indicating the same thing. Therefore, Counsel
believes the Court must dismiss this appeal. Therefore, pending the Court’s decision on
that issue, Counsel would request the Court extend the time to file brief in this matter.
II.
No prior extensions have been requested and is respectfully prayed that the in the
interest of justice, the Court grant this motion.
WHEREFORE, PREMISES CONSIDERED, undersigned counsel respectfully
prays that, in accordance with the applicable law, the Court grant this Motion and extend
the date by which to file a brief by thirty days.
Respectfully submitted,
/s/Austin Reeve Jackson
Texas Bar No. 24046139
112 East Line, Suite 310
Tyler, TX 75702
Telephone: (903) 595-6070
Facsimile: (866) 387-0152
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing document
was served on counsel for the State by facsimile concurrently with its filing.
/s/Austin Reeve Jackson