Charles Eugene Robertson v. State ( 2015 )


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  •                                                                                                ACCEPTED
    01-15-00376-CR
    FIRST COURT OF APPEALS
    HOUSTON, TEXAS
    7/30/2015 9:26:52 AM
    CHRISTOPHER PRINE
    CLERK
    NO. 01-15-00376-CR
    FILED IN
    1st COURT OF APPEALS
    CHARLES EUGENE                            §      IN THE         HOUSTON, TEXAS
    ROBERTSON                                 §                 7/30/2015 9:26:52 AM
    §                 CHRISTOPHER A. PRINE
    VS.                                       §      FIRST COURT        Clerk
    §
    STATE OF TEXAS                            §      OF APPEALS
    MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF
    TO THE HONORABLE JUSTICES OF SAID COURT:
    Now comes Charles Robertson, 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 452nd Judicial District Court of
    McCulloch County, Texas.
    2.      The case below was styled the STATE OF TEXAS vs. Charles Eugene
    Robertson, and numbered 5931.
    3.      Appellant was convicted of assault/family violence with a previous
    conviction.
    4.      Appellant was assessed a sentence of 10 years on February 17, 2015.
    5.      Notice of appeal was given on March 30, 2015.
    6.      The clerk's record was filed on April 6, 2015; the reporter's record was
    MOTION TO EXTEND TIME FOR BRIEF                                          Page 1 of 3
    filed on July 9, 2015.
    7.     The appellant’s brief is presently due on August 10, 2015.
    8.     Appellant requests an extension of time of thirty (30) days from August
    10, 2015. This would result in a new deadline of September 7, 2015.
    9.     No extension to file the brief has been received in this cause.
    10.    Defendant is currently incarcerated.
    11.    Appellant relies on the following facts as good cause for the requested
    extension:
    Appellant’s counsel has a brief due in the Eleventh Court of Appeals on
    August 17, 2015 in a case that is quite lengthy and involves four different cause
    numbers from the trial court.       Appellant’s counsel has already received two
    extensions in that case and will not be seeking another. Additionally, Appellant has
    discovery responses due in approximately five (5) civil cases during the week of
    August 3, 2015. Appellant therefore requests this extension to provide additional
    time to file the brief.
    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,
    The Haynes Law Firm, P.C.
    MOTION TO EXTEND TIME FOR BRIEF                                           Page 2 of 3
    309 N. Fisk
    Brownwood, Texas 76801
    Tel: (325) 646-2821
    Fax: (325) 643-3105
    By:
    Michael L. Smith
    State Bar No. 24072349
    E-Mail: msmith@haynesfirm.com
    Attorney for Appellant
    CERTIFICATE OF SERVICE
    This is to certify that on July 30, 2015, a true and correct copy of the above
    and foregoing document was served on the District Attorney's Office, McCulloch
    County, Texas, by e-service or fax.
    Michael L. Smith
    STATE OF TEXAS                           §
    §
    COUNTY OF BROWN                          §
    VERIFICATION
    "I am the attorney for the appellant in the above numbered and entitled
    cause. I have read the foregoing Motion To Extend Time to File
    Appellant's Brief and swear that all of the allegations of fact contained
    therein are true and correct."
    Michael L. Smith
    MOTION TO EXTEND TIME FOR BRIEF                                         Page 3 of 3
    

Document Info

Docket Number: 01-15-00376-CR

Filed Date: 7/30/2015

Precedential Status: Precedential

Modified Date: 9/29/2016