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ACCEPTED 12-14-00325-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 5/8/2015 12:23:51 PM CATHY LUSK CLERK No. 12-14-00325-CR TIMOTHY CORTEZ CHOICE § IN THE COURT OF APPEALS FILED IN Appellant § 12th COURT OF APPEALS TYLER, TEXAS § vs. § 12TH JUDICIAL 5/8/2015 DISTRICT 12:23:51 PM CATHY S. LUSK § Clerk THE STATE OF TEXAS, § Appellee § AT TYLER, TEXAS MOTION FOR ACCEPTANCE OF LATE BRIEF TO THE HONORABLE COURT: Now comes Austin Reeve Jackson, counsel for Appellant in the above entitled and numbered cause, and makes this Motion, and for good cause shows the following: I. Appellant’s brief in this matter was due on 28 April 2015 and is being filed concurrently with this motion. No prior extensions have been requested. II. While working on this case counsel has also been working on approximately 50 open appellate cases in this and other courts to which he has been appointed by Smith County. This has included investigating motions for new trials (looking for and talking with potential witnesses, jail and office visits with new appellate appointments, trial court appearances for the same), requests for and reviews of reporter’s and clerk’s records, research, briefing, review of opinions, investigation of potential PDR issues, etc. While not all of these seventy or so cases have required significant attention from counsel during this time, many of them have which ahs resulted form counsel having been able to devote the full attention necessary to this case prior to today’s date. Further, while working on this brief, counsel has also been preparing for and attending plea and trial settings in multiple cases in state and federal courts. Because of this, counsel was delayed in completing his brief in this matter. II. No prior extensions have been requested and it is respectfully prayed that, in the interest of justice, the Court accept the brief filed with this motion. WHEREFORE, PREMISES CONSIDERED, undersigned counsel respectfully prays that, in accordance with the applicable law, the Court grant this Motion and accept his brief in this matter. Respectfully submitted, /s/Austin Reeve Jackson Texas Bar No. 24046139 112 East Line, Suite 310 Tyler, TX 75702 Telephone: (903) 595-6070 Facsimile: (866) 387-0152 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing document was served on counsel for the State by facsimile concurrently with its filing. /s/Austin Reeve Jackson
Document Info
Docket Number: 12-14-00325-CR
Filed Date: 5/8/2015
Precedential Status: Precedential
Modified Date: 9/29/2016