Evender Gene Jackson v. State

ACCEPTED
06-15-00151-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
11/17/2015 11:22:13 AM
DEBBIE AUTREY
CLERK
NO. 6-15-00151CR
FILED IN
6th COURT OF APPEALS
STATE OF TEXAS § IN THE COURT TEXARKANA, TEXAS
11/17/2015 11:22:13 AM
§
DEBBIE AUTREY
vs. § OF APPEALS Clerk
§
EVENDER GENE JACKSON, JR. § SIXTH APPELATE DISTRICT
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Evender Gene Jackson, Jr., Appellant in the above styled and numbered
cause, and moves this Court to grant and extension of time to file Appellant's brief pursuant to
Rule 38.6 of the Texas Rules of Appellant Procedure and for good cause shows the following:
1. This case is on appeal from the 196th District Court, Hunt County, Texas;
2. The case below was styled State of Texas vs. Evender Gene Jackson, Jr.,
Cause Number 30,536.
3. Appellant was convicted of Aggravated Robbery with a Deadly Weapon.
4. Appellant was sentenced to 50 years in the Texas Department of Criminal
Justice, Institutional Division.
5. Notice of Appeal was given on August 14, 2015.
6. The Clerk's record was filed on October 13, 2015; The Reporter's record
was filed on October 12, 2015.
7. Appellant's brief is currently due on November 13, 2015.
8. Appellant requests an extension of time of 30 days from the current due
date.
9. No extension has previously been requested in this case.
10. Appellant relies on the following facts as good cause for the extension
requested:
Appellant's attorney, Jessica Edwards, has received the record but has had
insufficient time to adequately examine the record in order to effectively prepare a brief in this
case.
Counsel would also show this court that, since receiving the record in this case,
counsel was admitted to the hospital on October 26, 2015 and required an invasive surgical
procedure. Counsel is returning to work full time today, November 17, 2015. Counsel has had
insufficient time to review the record and prepare the brief.
WHEREFORE, PREMISIS CONSIDERED, Appellant prays that this Court
would grant Appellant's 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/ Jessica Edwards_____________
Jessica Edwards SBN: 24000994
P.O. Box 9318
Greenville, Texas 75404
Tel: (903) 513-0510
Fax: (903) 200-1359
E-Mail: jessicaedwardslaw@gmail.com
Attorney for Timothy Bates
CERTIFICATE OF SERVICE
This is to certify that on November 17, 2015, a true and correct copy of the above and
foregoing document was served on the Hunt County District Attorney's Office, by electronic
delivery.
/s/ Jessica Edwards
Jessica Edwards