Edwrick Quentria Bass v. State ( 2015 )

ACCEPTED 03-15-00628-CR 8215845 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/14/2015 10:11:13 AM JEFFREY D. KYLE CLERK NO. 03-15-00628-CR IN THE COURT OF APPEALS FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS THIRD DISTRICT OF TEXAS AT AUSTIN 12/14/2015 10:11:13 AM JEFFREY D. KYLE Clerk ******************************************************* CAUSE NO. 74,201 IN THE 426TH JUDICIAL DISTRICT COURT OF BELL COUNTY, TEXAS ******************************************************* EDWRICK QUENTRIA BASS APPELLANT VS. THE STATE OF TEXAS APPELLEE ******************************************************* APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF COMES NOW Appellant, EDWRICK QUENTRIA BASS, by and through his attorney of record, James H. Kreimeyer, and respectfully moves the Court to extend the time for filing the Appellant’s Brief in this cause, and in support hereof would show the Court as follows: I. On August 4, 2015, Appellant entered a plea of not guilty, to the offense of assault on a family member/dating relationship with prior misdemeanor convictions for assault causing bodily injury against a family member; and a jury found him guilty. The punishment assessed by the court was eleven years in the Texas Department of Criminal Justice, Institutional Division imposed on September 15, 2015. A notice of appeal was filed by appellant on October 7, 2015. II. Appellant’s Brief is due for filing with the Court of Appeals on December 14, 2015. III. Appellant’s attorney would respectfully request an extension of time to file Appellant’s brief. Counsel for appellant has just completed the appellate brief in Karl Lee Wiggins v. State, No. 03-15-00385-CR. The appellate record in this appellant’s appeal is nine (9) volumes. Counsel needs additional time to read the record and prepare the appellate brief. This Motion for Extension of Time is not filed for the purpose of delay, but so that the ends of justice may be served. WHEREFORE, PREMISES CONSIDERED, Appellant requests the Court to grant a forty five (45) day extension of time to file the brief herein until January 28, 2016. Respectfully submitted, /s/ James H. Kreimeyer JAMES H. KREIMEYER ATTORNEY FOR APPELLANT P.O. BOX 727 BELTON, TEXAS 76513 (254) 939-9393 (254) 939-2870 FAX T.S.B. #11722000 jkreime@vvm.com CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Appellant’s Motion for Extension of Time to File Brief was delivered to Henry Garza, District Attorney, Bell County Courthouse, Belton, Texas 76513, on the 14th day of December 2015. /s/ James H. Kreimeyer JAMES H. KREIMEYER ATTORNEY FOR APPELLANT