Bradley Allie v. State ( 2015 )

ACCEPTED 06-15-00100-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/14/2015 8:20:42 PM DEBBIE AUTREY CLERK IN THE COURT OF APPEALS SIXTH JUDICIAL DISTRICT OF TEXAS AT TEXARKANA FILED IN 6th COURT OF APPEALS BRADLEY ALLIE, TEXARKANA, TEXAS Appellant 12/15/2015 8:03:00 AM DEBBIE AUTREY vs. Appellate Cause Clerk No. 06-15-00100-CR THE STATE OF TEXAS, Appellee APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE BRIEF TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW the Appellant in the above styled and numbered cause and respectfully moves the Court in accordance with Tex. R. App. Pro. Rule 38.6 (d), to extend the time for filing Appellant's Brief in this cause, and in support therefore would respectfully show unto the Court as follows: I. The certified Clerk's Record was timely filed on the 4th day of September, 2015, and the certified Reporter's Record was timely filed on the 9th day of November, 2015, although the Reporter’s Record was not furnished to undersigned counsel until November 19, 2015. II. The current deadline for filing Appellant's Brief is the 17th day of December, 2015. III. The undersigned attorney has not had sufficient time to prepare Appellant's brief within the currently prescribed time allotted and hereby requests an additional thirty (30) days in which to prepare the brief. More specifically, in addition to his normal caseload, undersigned attorney has been preparing for pretrial hearings and trial in the following cases: 1 1. United States vs Kevin Bolton, Cause No. 6:14CR60003-001, United States District Court for the Western District of Arkansas, a potential federal death penalty case wherein the undersigned is currently developing the defendant’s mitigation case to be presented to the court at sentencing. 2. State of Texas vs. Diante Dennard, Cause No. 14F077-005, District Court of Bowie County, Texas; 3. Gaillard Builders, Inc. vs. R.E.C. Enterprises, LLC d/b/a Stan Excavating Co., Cause No. 46-CV-15-73, Circuit Court of Miller County, Arkansas. 4. United States of America vs. John William Vickers, Cause no. 4:15CR40028, United States District Court of the Western District of Arkansas. 5. United States of America vs. Jeffery N. Bain, Cause No. 4:15CR4002, United States District Court for the Western District of Arkansas. 6. United States of America vs. Bobby Charles Cooks, Cause No. 5:15CR00016, United States District Court for the Eastern District of Texas. 7. United States of America vs. Demetrice Mullens, Cause No. 5:15CR18(4), United States District Court for the Eastern District of Texas. 8. United States of America vs. Yuhanna Abdullah Sherriff, Cause No, 5:15CR17(02), United States District Court for the Eastern District of Texas. 9. United States of America vs. Eliezer Hernandez, Cause No. 5:15CR20, United States District Court for the Eastern District of Texas. 10. United States vs. Sandra Lockett, Cause No. 5:15CR9, United States District Court for the Eastern District of Texas. 2 IV. Appellant's attorney has not previously requested an extension of time to file the Brief in this cause. WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests this Honorable Court extend the time for filing his brief in this cause until the 18th day of January, 2016. Respectfully submitted, CRAIG L. HENRY Attorney at Law 723 Main Street P.O. Box 3226 Texarkana, Texas 75504-3226 (903) 792-4645 FAX - (903) 792-5073 Lawyrntx@aol.com By/s/ Craig L. Henry Craig L. Henry Arkansas Bar # 90142 Oklahoma Bar # 016779 Texas Bar # 09479260 Attorney for Appellant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Motion has been delivered electronically and via courier to Mr. Jerry Rochelle, Bowie County District Attorney, 601 Main Street, Texarkana, Texas 75501, this 14th day of December, 2015. /s/ Craig L. Henry Craig L. Henry 3