Joseph Tate Bailey v. State ( 2015 )

ACCEPTED
01-15-00215-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/15/2015 12:00:00 AM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00215-CR
FILED IN
JOSEPH BAILEY 1st COURT OF APPEALS
IN THE 1ST COURT OF APPEALS
HOUSTON, TEXAS
6/14/2015 3:19:49 PM
VS. HARRIS COUNTY TEXAS
CHRISTOPHER A. PRINE
Clerk
THE STATE OF TEXAS HOUSTON, TEXAS
MOTION FOR LEAVE TO FILE 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.
Appellant was convicted by a jury of Murder and was assessed a 35 year sentence.
II.
Appellant’s brief was due June 12, 2015.
Among other matters, professional and personal, Counsel has had numerous felony
briefs and writs recently, including two capital murders, namely, Ex Parte Rodriguez; Ex
Parte January; State of Texas vs. Pena; State of Texas vs.Agado; State of Texas vs.Adekeye.
Further, counsel’s immediate family member has recently suffered serious health
crises lately which counsel primarily assisted with.
IV.
Counsel has filed a Motion for Extension of Time to File Appellant’s Brief along with
this Motion for Leave to File, as it is two days after the due date.
Wherefore, premises considered, Counsel prays that this Honorable Court grant this motion,
grant a 60 day extension and permit the brief to be due on 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
Email: lanagordonlaw@aol.com
CERTIFICATE OF SERVICE
On this the 14 th day of June, 2015, this Motion was served upon the State of Texas,
Harris County District Attorney’s office by e-filing.
/s/ Lana Gordon
LANA GORDON