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ACCEPTED 12-14-00314-CR; 12-14-00315-CR; 12-14-316-CR; 12-14-00317-CR; 12-14-00318-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 5/20/2015 5:59:49 PM CATHY LUSK CLERK NO. 12-14-00314-CR; 12-14-00315-CR; 12-14-00316-CR; 12-14-00317-CR; 12-14-00318-CR FILED IN DANIEL WAYNE MCLEMORE. § IN THE TWELFTH COURT 12th COURT OFOF APPEALS Appellant, § TYLER, TEXAS § 5/20/2015 5:59:49 PM § CATHY S. LUSK VS. § APPEALS IN AND FORClerk § § THE STATE OF TEXAS, § Appellee. § THE STATE OF TEXAS MOTION TO EXTEND TIME TO FILE APPELANT BRIEF TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW DANIEL WAYNE MCLEMORE, by and through his attorney, Wm. Brandon Baade, and makes this MOTION TO EXTEND TIME TO FILE APPELANT BRIEF: 1. The deadline for filing the APPELANT’s Brief is May 8, 2015. 2. APPELANT seeks and extension of fourteen (14) days from the date of filing this motion or June 3, 2015 to file APPELANT’s Brief. 3. Facts relied on to reasonably explain the need for an extension: 4. On April 23, 2015 when the Appellant’s brief was due, Randy Hudiburgh, age 27, and relative through marriage to our family, and uncle to my grandchildren, killed himself in Portland, Texas. I was immediately busy assisting with my daughter and grandchildren, ages (4) and (2) in regard to this matter. 5. I consulted with counsel for the State regarding the filing of this Motion for an Extension of Time and counsel for the State of Texas does not oppose this motion and is in agreement with the request for extension of time. 6. Additionally, during the time since this tragedy counsel has been involved in the following cases: State of Texas v. Charles Eugene Louderman, Cause No. 21,728-2012 in the 402nd Judicial District Court in and for Wood County, Texas. State of Texas v.Nathaniel Lee Hurtzig, Cause No. 22,482-2015 in the 402nd Judicial District Court in and for Wood County, Texas. First National Bank of Winnsboro v. Melanie Windham, et al, Cause No. 2010-377 in the 402nd Judicial District Court in and for Wood County, Texas. State of Texas v. Clinton Eugene Sharp, Cause No. 22,383-2014 in the 402nd Judicial District Court in and for Wood County, Texas. State of Texas v. Wendy Gilbreath, Cause No. 22,410-2015 in the 402nd Judicial District Court in and for Wood County, Texas. State of Texas v. Heath Allen Nutt, Cause No.22,398-2014 in the 402nd Judicial District Court in and for Wood County, Texas. 4. APPELANT has been granted one (1) extension of time. WHEREFORE, DANIEL WAYNE MCLEMORE, by his attorney, Wm. Brandon Baade, requests the court extend time to file APPELANT’s Brief in this case. RESPECTFULLY SUBMITTED, Wm. Brandon Baade 522 N Broadway Ave Tyler, TX 75702 Tel: (903) 526-5867 brandonbaadelaw@gmail.com _______________________________ Wm. Brandon Baade State Bar No. 00793189 Attorney for Appelant CERTIFICATE OF CONFERENCE I certify that I have contacted Tom Burton, Attorney for Appellee, in this case and he is in agreement with this motion. _______________________________ Wm. Brandon Baade State Bar No. 00793189 Attorney for Appellant CERTIFICATE OF SERVICE I, the undersigned, hereby certify that a true and correct copy of the foregoing MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF was served on all counsel of record by U.S. Mail on May 20, 2015. _______________________________ Wm. Brandon Baade State Bar No. 00793189 Attorney for Appellant
Document Info
Docket Number: 12-14-00317-CR
Filed Date: 5/20/2015
Precedential Status: Precedential
Modified Date: 9/29/2016