Latori Devon Mosley v. State

ACCEPTED
12-16-00115-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
9/19/2016 10:14:54 PM
Pam Estes
CLERK
No. 12-16-00115-CR
LATORI DEVON MOSLEY § IN THE COURT OF APPEALS
FILED IN
Appellant § 12th COURT OF APPEALS
TYLER, TEXAS
§
vs. § 12TH JUDICIAL 9/19/2016
DISTRICT 10:14:54 PM
PAM ESTES
§ Clerk
THE STATE OF TEXAS, §
Appellee § AT TYLER, TEXAS
APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF
ONE DAY REQUEST
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 is due on 19 September 2016. Three 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 has resulted in counsel having been able to
devote the full attention necessary to this case prior to today’s date.
Because of this, counsel was delayed in completing his brief in this matter.
II.
Three prior extensions have been requested and it is respectfully prayed that in the
interest of justice, the Court grant this motion.
WHEREFORE, PREMISES CONSIDERED, undersigned counsel respectfully
prays that, in accordance with the applicable law, the Court grant this Motion and extend
the date by which to file a brief by one day.
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 efile concurrently with its filing.
/s/Austin Reeve Jackson