Alfred Dean Johnson v. State ( 2015 )

ACCEPTED
14-15-00046-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
5/26/2015 2:47:34 PM
CHRISTOPHER PRINE
CLERK
NO. 14-15-00046-CR
IN THE COURT OF APPEALS FILED IN
FOR THE FOURTEENTH DISTRICT OF TEXAS14thHOUSTON,
COURT OF APPEALS
TEXAS
5/26/2015 2:47:34 PM
CHRISTOPHER A. PRINE
ALFRED DEAN JOHNSON Clerk
Appellant
v.
THE STATE OF TEXAS
Appellee
On Appeal from Cause Number 1409436
From the 182nd District Court of Harris County, Texas
APPELLANT’S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE AN
APPELLATE BRIEF
To the Honorable Court of Appeals of Texas:
Comes now Appellant, in accordance with Rules 10.5(b)(1) and 38.6(d) of the
Texas Rules of Appellate Procedure, and files this motion for extension of time in
which to file the Appellant’s brief in this cause, and, in support thereof, presents the
following:
1. In the 182nd District Court of Harris County, Texas, following a
presentence investigation hearing, Appellant was sentenced on January 5,
2015 in Cause No. 1409436, The State of Texas v. Alfred Dean Johnson.
2. For the offense of Aggravated Robbery with a deadly weapon, Appellant
was sentenced to thirty years in the Texas Department of Corrections.
3. A written notice of appeal was timely filed on January 5, 2015.
4. The Appellant’s brief was due May 26, 2015.
5. An extension of time in which to file the Appellant’s brief is requested until
June 26, 2015.
6. Two previous extensions have been granted to the Appellant.
7. The facts relied upon to explain the need for this extension are:
a. Appellate counsel received a copy of the supplement to the appellate
record on April 15, 2015.
b. Due to other deadlines and trial settings that were already set during
May, appellate counsel needs additional time to complete the brief.
Consequently, additional time will be necessary in which to file Appellant’s
brief in this case. The Appellant’s motion is not for purposes of delay, but so that
justice may be done.
WHEREFORE, the Appellant prays that this Court will grant an additional
extension of time until June 26, 2015 in which to file Appellant’s brief in this cause.
2
Respectfully submitted,
LAW OFFICE OF TONYA ROLLAND
/s/ Tonya Rolland McLaughlin____
Tonya Rolland McLaughlin
4301 Yoakum Boulevard
Houston Texas 77006
Phone: (713) 529-8500
Fax: (713) 453-2203
TBN 24054176
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been emailed to
the following:
curry_alan@dao.hctx.net
Alan Curry
Chief Prosecutor, Appellate Division
Harris County District Attorney’s Office
1201 Franklin Suite 600
Houston, Texas 77002-1923
_/s/ Tonya Rolland McLaughlin__
Tonya Rolland McLaughlin
Attorney for Appellant
DATE: MAY 26, 2015
3