Jonathan Ray Shepherd v. State ( 2015 )

ACCEPTED
06-15-00064-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
10/19/2015 9:37:55 PM
DEBBIE AUTREY
CLERK
06-15-00064-CR
FILED IN
JONATHAN RAY SHEPHERD § IN THE SIXTH COURT OF OF APPEALS
6th COURT
§ TEXARKANA, TEXAS
vs. § APPEALS 10/20/2015 9:54:00 AM
§ DEBBIE AUTREY
STATE OF TEXAS § TEXAS Clerk
FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUDGE OF SAID COURT:
Now Comes , JONATHAN RAY SHEPHERD Appellant in the above styled matter, and brings
this his First Unopposed Motion for Extension of Time to File Brief pursuant to Tex. R. App.
10(b) and would show the Court as follows:
(A) the deadline for filing the item in question;
The current deadline for appellant to file his brief is October 16, 2015
(B) the length of the extension sought;
The appellant request that Court extend the deadline to file the appellant’s brief until
December 1, 2015.
(C) the facts relied on to reasonably explain the need for an extension; and
The record on this appeal is substantial. The reporter record is twenty volumes and fills an
entire banker’s box. This case involves a capital murder conviction wherein the defendant
received an automatic life sentence. Counsel has been on the appellate case for
approximately 45 days and has begun an exhaustive review of the record. Although, counsel
has diligently sought to complete the review and drafting of the appellate brief counsel was
not able to complete the drafting of the brief by the October 16, 2015 deadline.
(D) the number of previous extensions granted regarding the item in question
Counsel has not previously been granted an extension. The Court did extend the deadline for the
appellant to file the brief upon counsel’s substitution into this case.
FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF
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WHEREFORE, PREMISES CONSIDERED, JONATHAN RAY SHEPHERD prays
that the Court enter an order granting an extension until December 1, 2015 for the appellant to
file his brief.
Respectfully submitted,
The Law Office of Russell Wilson II
1910 Pacific Ave
Dallas, TX 75201
Tel: 4695730211
Fax: 972-704-2907
By:/S/ Russell Wilson II____________
Russell Wilson II
State Bar No. 00794870
Attorney for JONATHAN RAY SHEPHERD
CERTIFICATE OF SERVICE
This is to certify that on October 19, 2015, a true and correct copy of the above and
foregoing document was served on the Upshur County District Attorney's Office, by email.
S/ Russell Wilson II____________
Russell Wilson II
CERTIFICATE OF CONFERENCE
I conferred with opposing counsel regarding an extension of time in this case was notified that
counsel did not oppose this an extension of time
S/ Russell Wilson II____________
Russell Wilson II
FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF
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