Dequisha Jackson v. State ( 2015 )

ACCEPTED
12-15-00003-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
6/24/2015 12:00:58 PM
CATHY LUSK
CLERK
NO. 12-15-00003-CR
ON APPEAL FROM THE 159TH JUDICIAL DISTRICT COURTFILED IN
ANGELINA COUNTY, TEXAS 12th COURT OF APPEALS
TYLER, TEXAS
CAUSE NO. 2013-0731 6/24/2015 12:00:58 PM
CATHY S. LUSK
TH Clerk
DEQUISHA JACKSON § IN THE 12 COURT OF APPEALS
§
§ OF
vs. §
§
STATE OF TEXAS § TYLER, TEXAS
AMENDED MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Dequisha Jackson, Appellant in the above styled and numbered
cause, and moves this Court to grant an extension of time to file appellant's brief,
pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good
cause shows the following:
1. This case is on appeal from the 159th District Court of Angelina
County, Texas.
2. The case below was styled the STATE OF TEXAS vs. Dequisha
Jackson, and numbered 2013-0731. Appellant was convicted of Manslaughter.
4. Appellant was assessed a sentence of Fifteen (15) years in Texas
Department of Criminal Justice Institutional Division on December 17, 2015.
5. Notice of appeal was given on December 30, 2015.
6. The clerk's record was filed on February 17, 2015; the reporter's record
was filed on May 21, 2015.
7. The appellate brief was presently due on June 22, 2015.
8. Appellant requests an extension of time of thirty (30) days from the
current due date.
9. No extensions to file the brief have been received in this cause.
10. Defendant is currently incarcerated.
11. Appellant relies on the following facts as good cause for the requested
extension:
Counsel currently has a brief due in the 9th Court of Appeals this week that
contains over a thousand pages of transcript. Due to the complex nature of the trial
transcripts an additional brief due this week, Counsel will be unable to complete the
brief and will need an additional 30 days.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this
Court grant this Motion to Extend Time to File Appellant's Brief, and for such other
and further relief as the Court may deem appropriate.
Respectfully submitted:
/s/John D. Reeves
____________________
John D. Reeves
Attorney at Law
1007 Grant
Lufkin, Texas 75901
Phone (936) 632-160
Fax: (936) 632-1640
tessabellus@yahoo.com
SBOT # 16723000
Counsel for Appellant
CERTIFICATE OF CONFERENCE
Pursuant to Tex. R. App. 10.1 (5), certify that I, the undersigned conferred
with opposing counsel who is not opposed to an extension.
/s/John D. Reeves
___________________________
John D. Reeves
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing Appellant’s
Motion to Extend Time to file Appellant’s Brief on this 24h day of June, 2015
forwarded to State’s Attorney, April Ayers-Perez, Angelina County, by electronic
service at aprerez@angelinacounty.net.
/s/John D. Reeves
__________________________
John D. Reeves
Attorney for Appellant,
Dequisha Jackson