Joseph Tate Bailey v. State ( 2015 )

ACCEPTED
01-15-00215-CR
FIRST COURT OF APPEALS
FILED IN HOUSTON, TEXAS
st
1 COURT OF APPEALS 6/15/2015 12:00:00 AM
HOUSTON, TX CHRISTOPHER PRINE
CLERK
June 15, 2015
CHRISTOPHER A. PRINE, NO. 01-15-00215-CR
CLERK
FILED IN
JOSEPH BAILEY 1st OF
IN THE 1 ST COURT COURT OF APPEALS
APPEALS
HOUSTON, TEXAS
6/14/2015 3:04:36 PM
VS.
CHRISTOPHER A. PRINE
Clerk
THE STATE OF TEXAS HOUSTON, TEXAS
FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW LANA GORDON, Appointed counsel for Appellant,JOSEPH
BAILEY, who files this Motion and as grounds therefore would show as follows:
I.
Counsel was appointed to represent Mr. Bailey who was charged with Murder. Upon
a plea of not guilty, a jury convicted him of Murder in cause number 1411201 in the 248 th
District Court on February 24, 2015. Notice of Appeal was timely given after the jury
assessed punishment at 35 years in prison.
The brief was due June 12, 2015. Apologizing to this Honorable court for the late
filing of this Motion for Extension of Time to File Brief, Counsel requests one sixty day
extension.
II.
Counsel has had various professional and personal matters which made it impossible
to have the brief filed on the original due date of June 12, 2015.
Counsel also has other appellate cases to address: Ex Parte Taylor, Williams v. State,
Ex Parte January, Ex Parte Cain, Siros v. State and Adekeye v. State, including two capital
murders, among others.
Further, counsel is the primary person caring for an elderly, very ill relative now and
there have been various health crises she has addressed for him in the last month, taking
much of counsel’s time and energy.
II.
This case is complex, with complicated legal issues regarding a significant amount
of time to organize and present in a brief.
III.
Counsel requests one 60 day extension, causing the brief to be due August 12, 2015.
WHEREFORE, PREMISES CONSIDERED, Counsel prays that this Honorable Court
grant this Motion to Extend Time to File Appellant’s Brief and permit her to file it on or
before August 12, 2015.
Respectfully Submitted,
/s/ Lana Gordon
Lana Gordon
Counsel for Appellant
TBN: 08202700
3730 Kirby, Suite 1120
Houston, Texas 77098
TEL: (713) 520-5223
FAX: (713)520-5455
Lanagordonlaw@aol.com
CERTIFICATE OF SERVICE
On June 14, 2015, this Motion was served upon the State of Texas, Harris County
District Attorney’s office by e-service herein.
/s/Lana Gordon
LANA GORDON