Brandee Michelle Nichols v. State ( 2014 )

ACCEPTED
12-14-00287-cr
TWELFTH COURT OF APPEALS
TYLER, TEXAS
12/30/2014 10:47:47 AM
CATHY LUSK
CLERK
IN THE
TWELFTH COURT OF APPEALS
FILED IN
12th COURT OF APPEALS
CAUSE NO. 12-14-00287-CR TYLER, TEXAS
12/30/2014 10:47:47 AM
CATHY S. LUSK
BRANDEE MICHELLE NICHOLS § Clerk THE
ON APPEAL FROM
Appellant
VS. § 114TH DISTRICT COURT
THE STATE OF TEXAS,
Appellee § SMITH COUNTY, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE THE APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS AND THE JUSTICES THEREOF:
COMES NOW APPELLANT, BRANDEE MICHELLE NICHOL, the
Appellant, and moves the Court for an Extension of Time to File the Appellant’s Brief in this
cause and in support thereof would show the Court as follows:
I.
The Reporter’s Record was filed on December 3, 2014. According to the correspondence
the Appellant’s Brief is due to be filed on Friday, January 2, 2015.
II.
Appellant, respectfully request that pursuant to T.R.A.P. 10.5(d) 38.6 (d)
that the Court grant an Extension of Time to file Appellant’s Brief until the 3rd day of March,
2015, and in support thereof would respectfully show the Court that during the previous thirty
(30) days Counsel has been involved in the following:
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1. Appellant’s Counsel has also been involved in capital murder pre-trials in the case
styled the State of Texas v. Calvert in Smith County, Texas .
2. Undersigned Counsel has been involved with numerous federal cases and state
misdemeanor and felony cases.
3. Undersigned Counsel respectfully requests this Honorable Court to extend the time for
filing the Appellant’s Brief until the 3rd day of March, 2015, in order to afford the undersigned
Counsel the necessary time to conclude reading Appellant’s Record, researching the applicable
law and preparing the Appellant’s Brief.
WHEREFORE PREMISES CONSIDERED, the undersigned Counsel, respectfully prays
that his Honorable Court extend the time for filing Appellant’s Brief in this cause until the 3rd day
of March, 2015.
Respectfully submitted,
JEFF L. HAAS
Attorney at Law
908 First City Place
Tyler, Texas 75702
(903) 593-8338
Jeff L. Haas
JEFF L. HAAS
STATE BAR NO. 08659600
ATTORNEY FOR APPELLANT
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion for
Extension of Time to File Appellant’s Brief has been delivered to the District Attorney's Office of
Smith County, Texas, on this the 30th day of December, 2014.
Jeff L. Haas
JEFF L. HAAS
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