Chad Allen Bailey v. State ( 2015 )

ACCEPTED
05-15-00563-cr
FIFTH COURT OF APPEALS
DALLAS, TEXAS
7/1/2015 6:42:20 PM
LISA MATZ
CLERK
NO. 05-15-00563-CR
CHAD ALLEN BAILEY § FILED IN
§ IN THE COURT5th
OFCOURT OF APPEALS
APPEALS FOR
DALLAS, TEXAS
§
7/1/2015 6:42:20 PM
v. § THE FIFTH DISTRICT OF TEXAS
§ LISA MATZ
Clerk
THE STATE OF TEXAS § DALLAS, TEXAS
MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
NOW COMES, the Appellant, Chad Allen Bailey, and moves for an extension of time to
file the Appellant’s Brief in this case, and in support thereof would show the following:
I.
The appellant was convicted in the County Criminal Court Number Two, Dallas County,
Texas for the offense of driving while intoxicated in Cause No. MB13-34519-B, styled State of
Texas v. Chad Allen Bailey. On March 23, 2015, the appellant was assessed a punishment of 120
days confinement in the county jail, suspended for 15 months community supervision. A Motion
for New Trial was filed on March 25, 2015 and was denied. Notice of appeal was filed on April
13, 2015.
II.
The deadline for filing appellant’s brief in July 2, 2015. The appellant has not requested
any extension prior to this request.
III.
Appellant requests an extension of time of 30-days to file appellant’s brief. Counsel is
requesting the extension because counsel is preparing for trial in State v. Susan Aman, Cause No.
003-88432-2014 set on July 6, 2015, in Collin County and preparing for trial in State. v. Larry
Appellant’s Motion for Extension of Time to File Brie - Page 1
Foster, Cause No. M14-55737, set for trial July 8, 2015, in Dallas County.
IV.
WHEREFORE, appellant prays the court grant this motion and extend the deadline for
filing appellant’s brief for thirty-days until August 2, 2015.
Respectfully submitted,
/s/ Neil Pask ________
NEIL EDWARD PARK
State Bar of Texas Card No. 15556700
LAW OFFICE OF NEIL PASK, P.C.
6116 N. Central Expy.
Suite 500
Dallas, Texas 75206
(214) 360-9700
Fax (214) 891-9990
neil@paskcriminaldefense.com
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that a true and correct copy of the foregoing Motion for
Extension of Time to File Appellant’s Brief was mailed to the Dallas County District Attorney’s
Office, 133 N. Riverfront Blvd. Dallas, Texas 75207 on June 30, 2015.
____/s/ Neil Pask______________
Neil Pask
Appellant’s Motion for Extension of Time to File Brie - Page 2