Najma Parker v. State ( 2015 )

ACCEPTED 01-15-00334-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 7/27/2015 12:41:33 PM CHRISTOPHER PRINE CLERK NO. 0r-15-00334-CR FILED IN STATE OF TEXAS S rN TrrE 1st COURT OF APPEALS HOUSTON, TEXAS $ 7/27/2015 12:41:33 PM vs. s FrRST couRT CHRISTOPHER A. PRINE Clerk s I\AJMA PARKER S OF APPEALS MOTION TO E,XTEND TIME TO FILE APPE,LLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Najma Parker, 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 300th Judicial District Court of Brazoria County, Texas. 2. The case below was styled the STATE, OF TEXAS vs. Najma Parker, and numbered73269. 3. Appellant was convicted of Theft With Two Or More Previous Convictions. 4. Appellant was assessed a sentence of TDCJ-State Jail for a period of 2 years on 03/20/2015. 5. Notice of appeal was given on04ll0l20l5. 6. The clerk's record was filed on 0612512015; the reporter's record filed on 0511812015. 7 . The appellate brief is presently due on 07127 12015. 8. Appellant requests an extension of time of 30 days from the present date, i.e.07/27/2015. 9. No extension to file the brief has been received in this cause. 10. Defendant is currently ncarcerated. 1 1. Appellant relies on the following facts as good cause for the requested extension: Appellant's Counselhad several criminal trial cases to prepare for during this time period. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grarfi 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, FRANK J FRALEY 2616 South Loop West Suite 503 Houston, TX77054 Tel:713.668.4496 Fax:713.668.4497 Frank J. Fraley State Bar No. 07350350 fr aley fr ank@hotmail. c om Attorney for Najma Parker CERTIFICATE OF SERVICE This is to certify that on July 27, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Brazoria County, Jeri Yenne, by fax to 979.864.1525.