Steven Lamon Moore v. State ( 2015 )

ACCEPTED
12-15-00195-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
10/20/2015 4:51:30 PM
Pam Estes
CLERK
NO. 12-15-00195-CR
STEVEN LAMON MOORE § IN THE COURT OF APPEALS
§ FILED IN
vs. § 12th
TWELFTH JUDICIAL COURT OF APPEALS
DISTRICT
TYLER, TEXAS
§
STATE OF TEXAS § TYLER, TEXAS 10/20/2015 4:51:30 PM
PAM ESTES
Clerk
MOTION TO RECALCULATE DATES
FOR FILING THE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes 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 7th Judicial District Court of Smith County,
Texas.
2. The case below was styled State v. Steven Lamon Moore and numbered 007-
0446-15.
3. Appellant was convicted of Manufacture/Delivery of a Controlled Substance.
4. Appellant was assessed a sentence of thirty-five (35) years confinement in the
Texas Department of Criminal Justice-Institutional Division.
5. Notice of Appeal was given on August 5, 2015.
6. The Clerk's Record was filed on September 17, 2015; Jennifer Lowrance and
Beverly Dixon’s Reporters’ Records were filed on September 30, 2015. At the
time of this Motion, the Appellant has filed a Motion to Supplement with the
Twelfth Court of Appeals requesting the Pre-Sentence Investigation Report.
The Appellant’s brief is due November 2, 2015. However, this calculation was
made prior to the needing the supplementation of the Clerk Record. Counsel
requests the Court recalculate the brief deadline based on 30 days following the
completion of the record in this case. TEX. R. APP. P. 38.6.
7. Appellant requests that the Court grant this Motion and recalculate the
deadline dates for filing the Appellant’s Brief and further relief as the Court
may deem appropriate.
Respectfully submitted,
Law Office of James W. Huggler, Jr.
100 E. Ferguson, Suite 805
Tyler, Texas 75702
Tel: (903) 593-2400
Fax: (903) 593-3830
By: /S/ James W. Huggler, Jr.
James W. Huggler, Jr.
State Bar No. 00795437
Attorney for APPELLANT
CERTIFICATE OF SERVICE
This is to certify that on October 20, 2015, a true and correct copy of the above
and foregoing document was served on Michael West, Smith County District Attorney's
Office, 100 North Broadway, Tyler, Texas 75702, by regular mail, fax, hand delivery,
or electronic filing.
/S/ James W. Huggler, Jr.
James W. Huggler, Jr.