DeAndre Dwight Joseph A/K/A Joseph DeAndre A/K/A DeAndre Dwight Parks A/K/A/ DeAndre Parks A/K/A DeAndre Joseph A/K/A DeAndra Dwight Joseph v. State ( 2015 )

ACCEPTED
03-15-00209-CR
5583657
THIRD COURT OF APPEALS
June 8, 2015 AUSTIN, TEXAS
6/8/2015 1:43:08 PM
JEFFREY D. KYLE
CLERK
IN THE
THIRD COURT OF APPEALS
OF TEXAS
DEANDRE DWIGHT JOSEPH §
§
V. § CAUSE NUMBER 03-15-00209-CR
§
THE STATE OF TEXAS §
APPELLANT’S MOTION TO EXTEND THE TIME
TO FILE THE APPELLATE BRIEF
TO THE HONORABLE THIRD COURT OF APPEALS:
Deandre Dwight Joseph files Appellant’s Motion To Extend The Time To
File The Appellate Brief and would show as follows:
I.
Appellant was convicted of aggravated assault and attempted arson in State
of Texas v. Deandre Dwight Joseph, Cause Number D-1-DC-15-904009 in the
403rd District Court of Travis County. The jury assessed his punishment at 54
years in prison for aggravated assault and 25 years for attempted arson on March
11, 2015. Appellant gave timely notice of appeal.
II.
The appellate brief is due on June 15, 2015. Appellant requests an extension
of time until July 31, 2015, to file the brief.
III.
The court has not previously granted an extension of time.
IV.
For good cause, appellant would show that appellate counsel, Randy
Schaffer, will not have sufficient time to prepare the brief by June 15 because he
was hired on June 3 and has requested, but does not yet have, the appellate record.
Counsel has a suppression hearing on June 26 in State v. Ballard, No. 14-07-
07804, in the 359th District Court of Montgomery County and must file a brief in
Bezerra v. State, No. 07-15-00018-CR, in the Seventh Court of Appeals by June
26. Counsel will not be able to commence preparation of appellant’s brief before
June 27.
Appellant moves that the court extend the time to file the appellate brief to
July 31, 2015.
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Respectfully submitted,
/s/ Randy Schaffer
State Bar No. 17724500
1301 McKinney, Suite 3100
Houston, Texas 77010
(713) 951-9555
(713) 951-9854 (facsimile)
noguilt@swbell.net
Attorney for Appellant
DEANDRE DWIGHT JOSEPH
CERTIFICATE OF SERVICE
I served a copy of this document on Rosemary Lehmberg, District Attorney,
Travis County Courthouse, P.O. Box 1748, Austin, Texas 78767, by United States
mail, postage prepaid, on June 8, 2015.
/s/ Randy Schaffer
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