Mickey Lee Bates v. State ( 2015 )

ACCEPTED
06-14-00096-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
7/8/2015 5:07:59 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00096-CR
MICKEY LEE BATES § IN THE SIXTH COURT OFIN
FILED
6th COURT OF APPEALS
§ TEXARKANA, TEXAS
VS. § APPEALS , TEXARKANA
7/8/2015 5:07:59 PM
§ DEBBIE AUTREY
STATE OF TEXAS § TEXAS Clerk
MOTION TO EXTEND TIME TO
FILE MOTION FOR REHEARING
TO THE HONORABLE JUDGES OF SAID COURT:
Now comes Mickey Lee Bates, Appellant in the above styled and numbered
cause, and moves for an extension of 30 days to file a Motion for Rehearing, and
for good cause shows the following:
1. On June 17, 2015, the Court of Appeals affirmed appellant's
conviction. Mickey Lee Bates, v. State. The last day for filing a Motion to
Extend Time to file a Motion for Rehearing pursuant to Rule 49.8 of the Rules of
Appellate Procedure is July 17, 2015 .
2. Counsel has been unable to complete the petition for the following
reasons:
3. Counsel attended the Rusty Duncan Criminal Defense Seminar and
was out of town from June 17, 2015 through June 21, 2015.
4. Counsel had Child Protective Services docket in the Lamar County
Court at Law on June 23, 2015 and had hearings in four different cases. In
addition, the undersigned had two probate hearings in the Lamar County Court at
Law on this date, and a final pretrial docket in the Lamar County Court, in a case
styled State v. Ketchum.
5. Counsel had a scheduled pretrial hearing on various Motions in the
Lamar County Court, in Ketchum v. State on June 29, 2015.
6. Counsel has a jury trial set for July 7, 2015 in a case styled State v.
Ketchum in the Lamar County Court (Jury selection).
7. Counsel had a scheduled mediation on July 9, 2015 in a case styled
Julie Dominguez and Christina Yarbrough v. Cristal Rogers. (Cancelled on July 8,
2015, because of opposing Counsel’s medical emergency.
8. Counsel has a hearing in a case styled In the Interest of H.R.H., on
July 14, 2015 in the Lamar County Court at Law.
9. Counsel is scheduled to continue trying case styled State v. Ketchum
on January 20, 2015.
10. Defendant is currently incarcerated.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully
requests an extension of 30 days, i.e. until August 16, 2015, to file a Motion for
Rehearing in this cause.
Respectfully submitted,
Gary L. Waite
104 Lamar Ave.
Paris, Texas 75460
(903) 785-0096
(903) 785-0097
By:/s/ Gary L. Waite
Gary L. Waite
State Bar No. 20667500
garywaite@sbcglobal.net
A ttorney for M ickey Lee Bates,
01925935
CERTIFICATE OF SERVICE
This is to certify that on July 8, 2015, 2015, a true and correct copy of the
above and foregoing document was served on the County Attorney's Office, Lamar
County, 119 N. Main, Paris, Texas 75460, by personal delivery.
/s/Gary L. Waite
Gary L. Waite