State of Texas v. Jackson, John Berry ( 2014 )

PD-0823-14 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 12/29/2014 12:48:10 PM December 29, 2014 Accepted 12/29/2014 3:57:00 PM No. PD-0823-14 ABEL ACOSTA CLERK TO THE COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS THE STATE OF TEXAS, Appellant v. JOHN BERRY JACKSON, Appellee Appeal from Mitchell County ****** JOHN BERRY JACKSON’S MOTION TO EXTEND TIME FOR FILING HIS BRIEF ON DISCRETIONARY REVIEW ****** Jeffrey A. Propst Attorney for Appellee, John Berry Jackson Texas Bar No. 24064062 P.O. Box 3717 Abilene, Texas 79604 Tel. (325) 455-1599 Fax (325) 455-1507 Email: jeff@keithandpropst.com No. PD-0823-14 TO THE COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS THE STATE OF TEXAS, Appellant v. JOHN BERRY JACKSON, Appellee ****** JOHN BERRY JACKSON’S MOTION TO EXTEND TIME FOR FILING HIS BRIEF ON DISCRETIONARY REVIEW ****** TO THE HONORABLE COURT OF CRIMINAL APPEALS: Pursuant to the Rules of Appellate Procedure, Appellee John Berry Jackson moves this Honorable Court to extend the time for filing his brief 15 days - until January 13, 2015. Mr. Jackson’s brief is currently due for filing on December 29, 2014. No previous motions to extend the deadline for filing the brief have been filed. In the last 30 days the undersigned counsel’s caseload has included a three- day jury trial, the filing of an appellate brief to the United States Court of Appeals for the Fifth Circuit, and multiple other hearings and appointments. Due to the undersigned counsel’s caseload and administrative duties, as well as the disruptive effect on business of the holiday season, counsel needs additional time to prepare the Appellee’s brief. WHEREFORE, the Appellee prays that his motion to extend the time for filing his brief until January 13, 2015, be granted. Respectfully submitted, /s/ Jeffrey A. PROPST JEFFREY A. PROPST Texas Bar No. 24064062 P.O. Box 3717 Abilene, Texas 79604 Tel. (325) 455-1599 Fax (325) 455-1507 Email: jeff@keithandpropst.com CERTIFICATE OF SERVICE I, Jeffrey A. Propst, hereby certify that on December 29, 2014, a copy of the Appellee’s Motion to Extend Time for Filing his Brief on Discretionary Review was served via certified electronic service provider to: Lisa McMinn State Prosecuting Attorney P.O. Box 13046 Austin, Texas 78711 information@spa.texas.gov Barrett Thomas Assistant District Attorney 100 E. 3rd St., Suite 202 Sweetwater, Texas 79556 barrett@32ndda-tx.us /s/ Jeffrey A. Propst JEFFREY A. PROPST Attorney for John Berry Jackson