Charles Dewayne Hooks v. State ( 2015 )

ACCEPTED
05-15-00186-CR
FIFTH COURT OF APPEALS
DALLAS, TEXAS
7/9/2015 10:20:31 AM
LISA MATZ
CLERK
NO. 05-15-00186-CR
FILED IN
5th COURT OF APPEALS
CHARLES DEWAYNE HOOKS § IN THE COURT OF APPEALS
DALLAS, TEXAS
7/9/2015 10:20:31 AM
V. § FOR THE FIFTH DISTRICT
LISA MATZ
Clerk
STATE OF TEXAS § OF TEXAS AT DALLAS
MOTION FOR AN EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW, Charles Dewayne Hooks, Appellant in the above
named cause numbers, by and through his duly appointed attorney on
appeal, and requests that this Court extend the time for filing Appellant’s
brief from July 12, 2015 to August 11, 2015.
I.
On February 5, 2015, Appellant pled guilty and was convicted of
murder in the 283rd Judicial District Court in Dallas County, Texas. (CR:
59). The jury found Appellant guilty and sentenced Appellant to life
imprisonment. (CR: 59). On February 5, 2015, Appellant filed a timely
notice of appeal. (CR1: 26).
II.
The due date for Appellant’s Brief is July 12, 2015.
III.
Appellant requests an extension of time of thirty (30) days in which to
file his Brief. No previous extension of time has been requested by
Appellant.
IV.
Appellant submits that a reasonable explanation exists for this
requested extension. Appellant relies on the following facts to reasonably
explain why the brief has not yet been prepared and the need for an
extension of time in which to file Appellant’s Brief:
(1) The undersigned attorney filed a brief in cause numbers 06-14-
00234-CR & 06-14-00235-CR styled Melvin Wayne Richardson v.
State of Texas on April 20, 2015 pending in the 6th District Court of
Appeals, Texarkana, Texas.
(2) The undersigned attorney filed a brief in cause numbers 05-14-
01075-CR styled Jorge Gutierrez v. State of Texas on April 24, 2015
pending in the 5th District Court of Appeals, Dallas, Texas.
(3) The undersigned attorney filed a brief in cause numbers 05-14-
01251-CR and 05-14-01252-CR styled Lavandra Donteka Rushing v.
State of Texas on May 22, 2015 pending in the 5th District Court of
Appeals, Dallas, Texas.
(4) The undersigned attorney filed a brief in cause number 05-14-
01369-CR styled Ronnie Creige Wilson v. State of Texas on May 27,
2015 pending in the 5th District Court of Appeals, Dallas, Texas.
(5) The undersigned attorney filed a brief in cause number 05-14-
01122-CR styled Vicente Alejandro Perez v. State of Texas on June
24, 2015 pending in the 5th District Court of Appeals, Dallas, Texas.
(6) The undersigned attorney filed a brief in cause numbers 05-14-
01308-CR and 05-14-01309-CR styled Gerardo DeLaCruz v. State of
Texas on July 6 , 2015 pending in the 5th District Court of Appeals,
Dallas, Texas.
(7) The undersigned attorney is preparing a brief in cause number 05-
14-01445-CR styled Lakeisha Shanta Hill v. State of Texas pending in
the 5th District Court of Appeals, Dallas, Texas.
(8) The undersigned attorney is preparing a brief in cause number 05-
14-01609-CR styled Ricardo Velazquez v. State of Texas pending in
the 5th District Court of Appeals, Dallas, Texas.
V.
This Motion is not brought for purposes of delay but so that the
appellate record can be read and evaluated, and so that the legal and factual
issues presented by the appellate record can be properly briefed and
presented to this Court on Appellant’s behalf.
WHEREFORE, Appellant requests this Court extend Appellant’s
deadline to file its brief to August 11, 2015.
Respectfully submitted,
/s/ Nanette Hendrickson
Lynn Pride Richardson Nanette Hendrickson
Chief Public Defender Assistant Public Defender
Dallas County, TX Texas State Bar No. 24081423
Frank Crowley Courts Building
133 N. Riverfront Blvd., LB-2
Dallas, Texas 75207-4399
(214) 653-3582 (phone)
(214) 653-3539 (fax)
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing motion was served
on the Dallas County Criminal District Attorney’s Office (Appellate
Division), 133 N. Riverfront Blvd., B-19, 10th Floor, Dallas, Texas, 75207,
by hand delivery and electronic service at DCDAAppeals@dallascounty.org
on July 9, 2015.
/s/ Nanette Hendrickson
Nanette Hendrickson