Valerie Salyards Gilmore v. State ( 2015 )

ACCEPTED
12-15-00049-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
5/8/2015 12:28:27 PM
CATHY LUSK
CLERK
No. 12-15-00049-CR
VALERIE GILMORE § IN THE COURT OF APPEALS
FILED IN
Appellant § 12th COURT OF APPEALS
TYLER, TEXAS
§
vs. § 12TH JUDICIAL 5/8/2015
DISTRICT 12:28:27 PM
CATHY S. LUSK
§ Clerk
THE STATE OF TEXAS, §
Appelle § AT TYLER, TEXAS
MOTION FOR ACCEPTANCE OF LATE BRIEF
TO THE HONORABLE COURT:
Now comes Austin Reeve Jackson, counsel for Appellant in the above entitled and
numbered cause, and makes this Motion, and for good cause shows the following:
I.
Appellant’s brief in this matter was due on 31 April 2015 and is being filed
concurrently with this motion. No prior extensions have been requested.
II.
While working on this case counsel has also been working on approximately 50
open appellate cases in this and other courts to which he has been appointed by Smith
County. This has included investigating motions for new trials (looking for and talking
with potential witnesses, jail and office visits with new appellate appointments, trial court
appearances for the same), requests for and reviews of reporter’s and clerk’s records,
research, briefing, review of opinions, investigation of potential PDR issues, etc. While
not all of these seventy or so cases have required significant attention from counsel
during this time, many of them have which ahs resulted form counsel having been able to
devote the full attention necessary to this case prior to today’s date.
Further, while working on this brief, counsel has also been preparing for and
attending plea and trial settings in multiple cases in state and federal courts.
Because of this, counsel was delayed in completing his brief in this matter.
II.
No prior extensions have been requested and it is respectfully prayed that, in the
interest of justice, the Court accept the brief filed with this motion.
WHEREFORE, PREMISES CONSIDERED, undersigned counsel respectfully
prays that, in accordance with the applicable law, the Court grant this Motion and accept
his brief in this matter.
Respectfully submitted,
/s/Austin Reeve Jackson
Texas Bar No. 24046139
112 East Line, Suite 310
Tyler, TX 75702
Telephone: (903) 595-6070
Facsimile: (866) 387-0152
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing document
was served on counsel for the State by facsimile concurrently with its filing.
/s/Austin Reeve Jackson