Dorsey Nathaniel Carr III v. State ( 2015 )

ACCEPTED 01-15-00246-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 7/21/2015 1:40:02 PM CHRISTOPHER PRINE CLERK Cause No. 01-15-00246-CR FILED IN DORSEY NATHANIEL CARR, III * IN THE COURT 1st OF COURT APPEALSOF APPEALS APPELLANT * HOUSTON, TEXAS * 7/21/2015 1:40:02 PM V. * FIRST DISTRICT CHRISTOPHER A. PRINE Clerk * THE STATE OF TEXAS, * APPELLEE * HOUSTON, TEXAS MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF Comes now DORSEY NATHANIEL CARR, III, through his attorney of record John J. Davis, and files this Motion For An Extension of Time in which to file Appellant's Brief pursuant to Rules 10.5(b) and 38.6(d) of the Texas Rules of Appellate Procedure. In support of this Motion, Appellant shows the Court the following: I. TRIAL COURT: 239th District Court of Brazoria County, Texas, Judge Patrick Sebesta, presiding. CAUSE NUMBER: 74,219 STYLE: The State of Texas vs. Dorsey Nathaniel Carr, III DATE OF JUDGMENT: February 20, 2 015 CONVICTION (OFFENSE): Felony DWI Enhanced SENTENCE: Ten (10) years TDCJ-ID. DEADLINE FOR FILING APPELLANT'S BRIEF: July 22, 2015 LENGTH OF TIME REQUESTED FOR EXTENSION: August 21, 2015 (30 days) NUMBER OF PREVIOUS EXTENSIONS GRANTED: None II. REASONS FOR EXTENSION Appellant's request for an extension is based upon the following facts: Counsel is the defense counsel for the Brazoria County Drug Court which meets every week and requires additional time for client conferences. Counsel is also the appointed defense counsel at probation reviews in the 149th and 239th District Courts as well as the appointed defense counsel for the jail dockets in County Court at Law Number 1 of Brazoria County. Counsel's case load and the settings and requirements of the drug court and the review and jail dockets coupled with the need of a sole practitioner to meet with clients and maintain some semblance of a cash flow have resulted in Counsel being unable to finish the brief by the stated deadline. WHEREFORE, PREMISES CONSIDERED, Appellant prays the Court grant this MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF and extend the time for filing the Brief until August 21, 2015. Respectfully submitted, /s/ John J. Davis John J. Davis P.O. Box 787 2 05 N. Chenango Angleton, Texas 77516-0787 SBN 05515500 Telephone: (979) 849-4362 d.attorne@sbcglobal.net ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF was served to: Jeri Yenne Criminal District Attorney Brazoria County Courthouse 111 East Locust, Suite 408A Angleton, Texas 77515 ATTENTION: David Bosserman VIA FACSIMILE (979) 864-1525 on the 21st day of July, 2015 /s/ John J. Davis John J. Davis Attorney for Appellant