Devon Ray Davis v. State ( 2015 )

ACCEPTED
06-15-00032-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
5/21/2015 1:52:58 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00032-CR
FILED IN
6th COURT OF APPEALS
DEVON RAY DAVIS § IN THE COURTTEXARKANA, TEXAS
5/21/2015 1:52:58 PM
§ DEBBIE AUTREY
VS. § OF APPEALS Clerk
§
§STATE OF TEXAS SIXTH APPELLATE DISTRICT
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Devon Ray Davis, 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 196th Judicial District Court of Hunt
County, Texas.
2. The case below was styled State of Texas v. Devon Ray Davis, Cause
No. 22,886.
3. Appellant was convicted in Cause 22,886 of Robbery and was
sentenced to sixty (60) years in the Texas Department of Corrections, Institutional
Division.
4. Notice of appeal was given on February 13, 2015.
6. The clerk's record in this case was filed on February 27, 2015 and the
Supplemental Clerk’s Record was filed April 11, 2015; the reporter's record in this
case was filed on February 27, 2015.
7. The appellate brief in this case is presently due on May 11, 2015.
8. Appellant requests an extension of time of forty-five (45) days from the
present date.
9. No extension to file the brief has been received in this case.
10. Defendant is currently incarcerated.
11. Appellant relies on the following facts as good cause for the requested
extension:
Appellant’s attorney, Katherine A. Ferguson, has requested the record, but
Appellant’s attorney requests additional time to sufficiently analyze the material
contained in the lower court proceedings in order to effectively prepare a brief in
this case.
Appellant’s Counsel further shows that counsel was working on a brief due in
the Twelfth Court of Appeals on May 4, 2015 2014 in cause no. 12-14-00365-CV,
styled Edom Corner, LLC and Earl A. Berry, Jr. v. It’s the Berry’s, LLC d/b/a Mary
Ellen’s.
Appellant has conferred with counsel for the State of Texas and the State of
Texas does not oppose the requested extension.
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,
RENSHAW, DAVIS & FERGUSON, LLP
By: /s/ Katherine A. Ferguson
Katherine A. Ferguson
(SBN 06918050)
2900 Lee Street, Suite 102
P.O. Box 21
Greenville, Texas 75403-0021
Tel: (903) 454-6050
Fax: (903) 454-4898
Email: fergusk66@gmail.com
CERTIFICATE OF SERVICE
This is to certify that on May 21, 2014, a true and correct copy of the above
and foregoing document was served on the Hunt County District Attorney's Office,
Hunt County Courthouse, 4th Floor, Greenville, Texas by hand delivery.
/s/ Katherine A. Ferguson
Katherine A. Ferguson