Michael Brent Brown v. State ( 2015 )


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  •                                                                                       ACCEPTED
    01-15-00042-cr
    FIRST COURT OF APPEALS
    HOUSTON, TEXAS
    6/1/2015 11:33:41 AM
    CHRISTOPHER PRINE
    CLERK
    NO. 01-15-00042-CR
    STATE OF TEXAS                        §   IN THE                 FILED IN
    1st COURT OF APPEALS
    §                       HOUSTON, TEXAS
    VS.                                   §   1st COURT       6/1/2015 11:33:41 AM
    §                   CHRISTOPHER A. PRINE
    MICHAEL BROWN                         §   OF APPEALS              Clerk
    MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
    TO THE HONORABLE JUSTICES OF SAID COURT:
    Now comes Michael Brown, 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 163rd Judicial District Court of
    Orange County, Texas.
    2.   The case below was styled the State of Texas vs. Michael
    Brown, and numbered B-140,443-R.
    3.   Appellant was    convicted   of Possession    of a   Controlled
    Substance.
    4.   Appellant was assessed a sentence of Life on December 11,
    2014.
    5.   Notice of appeal was given on December 16, 2014.
    6.    The clerk's record was filed on March 25, 2015; the reporter's
    record was filed on February 25, 2015.
    7.    The appellate brief is presently due on May 26, 2015.
    8.    Appellant requests an extension of time of 30 days from the
    present date, i.e. June 24, 2015.
    9.    One extension to file the brief has been received in this cause.
    10.   Defendant is currently ncarcerated.
    11.   Appellant relies on the following facts as good cause for the
    requested extension:
    The Attorney for Appellant has been laboring under a heavy caseload
    and requires more time to prepare said brief.
    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,
    CHRISTINE R BROWN-ZETO
    Attorney at Law
    1107 Green Avenue
    Orange, Texas 77630
    Tel: (409) 886-8558
    Fax: (409) 883-6523
    By: /s/ Christine R. Brown-Zeto
    Christine R. Brown-Zeto
    State Bar No. 03102200
    crbrownzeto@sbcglobal.net
    Attorney for Michael Brown
    CERTIFICATE OF SERVICE
    This is to certify that on May 4, 2015, a true and correct copy of the
    above and foregoing document was served on the District Attorney's
    Office, Orange County, 801 Division, Orange, Texas 77630, by personal
    delivery.
    /s/ Christine R. Brown-Zeto
    Christine R. Brown-Zeto
    STATE OF TEXAS                        §
    §
    COUNTY OF ORANGE                      §
    AFFIDAVIT
    BEFORE ME, the undersigned authority, on this day personally
    appeared Christine R. Brown-Zeto, who after being duly sworn stated:
    "I am the attorney for the appellant in the above numbered and
    entitled cause.   I have read the foregoing Motion To Extend
    Time to File Appellant's Brief and swear that all of the
    allegations of fact contained therein are true and correct."
    /s/ Christine R. Brown-Zeto
    Christine R. Brown-Zeto
    Affiant
    SUBSCRIBED AND SWORN TO BEFORE ME on May 4, 2015, to
    certify which witness my hand and seal of office.
    /s/ Chrystal Murphy
    Notary Public, State of Texas
    My Commission Expires: June 2, 2018
    

Document Info

Docket Number: 01-15-00042-CR

Filed Date: 6/1/2015

Precedential Status: Precedential

Modified Date: 9/29/2016