Larry Joe Jones v. State ( 2015 )

ACCEPTED
06-15-00124-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
11/9/2015 3:39:58 PM
DEBBIE AUTREY
CLERK
CAUSE NO. 06-15-00124-CR
LARRY JOE JONES § IN THE SIXTH FILED IN
§ 6th COURT OF APPEALS
TEXARKANA, TEXAS
V. § COURT OF APPEALS
11/9/2015 3:39:58 PM
§
DEBBIE AUTREY
STATE OF TEXAS § OF THE STATE OF TEXAS Clerk
MOTION TO EXTEND DEADLINE FOR FILING APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW, Larry Joe Jones, the Appellant, in the above styled and numbered
cause, and files this motion for an extension to December 9, 2015, to file the appellate
brief. In support of this motion, appellant shows the following:
I.
The appellant was tried for the offense of Evading Arrest, in Brazos County, Texas,
under Cause Number 14-02769-CRF-85. At the conclusion of the trial, the jury found the
appellant guilty, and he was sentenced to seventy-five years in the Texas Department of
Criminal Justice on May 5, 2015. A timely notice of appeal was filed in this case. The
appellant's brief is due December 9, 2015.
II.
The reason for the extension of the deadline to file the appellant’s brief is based on
the following:
Appellant's counsel is scheduled to go to trial in Cause No. D1GN14000461, in the
261st District Court of Travis County, Texas, on November 16, 2015. Because of
preparation for this impending trial, counsel requires some more time to complete a
thorough review and briefing of the issues in this case.
For these reasons, counsel moves that the deadline for the brief be extended until
December 9, 2015.
RESPECTFULLY SUBMITTED,
/s/ David W. Crawford
David W. Crawford
State Bar No. 24031601
Crawford and Cruz PLLC
P.O. Box 1510
Austin, Texas 77806
Telephone (979) 575-9871
Telefacsimile (512) 237-7792
Email: dcrawford@crawfordcruz.com
Attorney for Appellant
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing instrument
has been furnished to the Attorney for the State presently assigned to this case, via fax.
Date: November 9, 2015
/s/ David W. Crawford
Attorney for Appellant
CAUSE NO. 06-15-00124-CR
LARRY JOE JONES § IN THE SIXTH
§
V. § COURT OF APPEALS
§
STATE OF TEXAS § OF THE STATE OF TEXAS
ORDER
On this day of ______________, 201___, came to be heard Appellant’s Motion for
Extension of Time to File Appellant’s Brief, and it appears to the court that this motion
should be:
_________ GRANTED
_________ DENIED
IT IS THEREFORE ORDERED that the time for filing the appellant’s brief in Cause No.
06-15-00124-CR ____________ be extended to _______________, 201__.
SIGNED and ENTERED this __ day of ____________, 201__.
__________________________
JUDGE PRESIDING