Willie Frank Jackson v. State

ACCEPTED
06-14-00097-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
1/28/2015 5:30:37 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00097-CR
FILED IN
6th COURT OF APPEALS
STATE OF TEXAS § IN THE TEXARKANA, TEXAS
§ 1/28/2015 5:30:37 PM
VS. § 6th COURT DEBBIE AUTREY
§ Clerk
WILLIE FRANK JACKSON § OF APPEALS
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF 2nd
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Willie Frank 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 354TH Judicial District Court of Hunt
County, Texas.
2. The case below was styled the STATE OF TEXAS vs. Willie Frank
Jackson, and numbered 29,295.
3. Appellant was convicted of Aggravated Robbery, with a Deadly
Weapon.
4. Appellant was assessed a sentence of 90 years on May 14, 2014.
5. Notice of appeal was given on May 14, 2014.
6. The clerk's record was filed on September 10, 2014; the reporter's
record was filed on November 25, 2014.
7. The appellate brief is presently due on January 28, 2015.
8. Appellant requests an extension of time of 30 days from the present
date.
9. One extension to file the brief has been received in this cause.
10. Defendant is currently incarcerated.
11. Appellant relies on the following facts as good cause for the requested
extension:
Appellant’s attorney, Jason A. Duff has begun a review the several volumes in
the reporter’s record and the clerk’s record the record; however, Appellant’s counsel
requests additional time to sufficiently develop the arguments material to the brief.
Additionally, Counsel was out of state from January 1, 2015 through January
6, 2015.
Counsel was set on a special setting for trial in Cause No 80,371, In the
Interest of K.L.M. in the 196th District Court; Hunt County Child Protection Court
for Northeast Texas #2 on January 21 and 22, 2015.
Counsel was just appointed on In the Interest of N.G.J. Appellate Cause No.
06-14-00083-CV, an accelerated appeal, and is working quickly to become
acquainted with the parties and issues of that case.
Counsel is also appointed in:
Garza v. State Appellate Cause numbers 06-14-00088-CR through
06-14-00093, and filed multiple briefs relating to that case December 22, 2014,
Counsel is appointed in Semaj Milan Yrnah Smith v. State, Appellate Cause
No. 06-14-00158-CR and filed a brief on December 23, 2014,
Young v. State Appellate Cause number 06-14-00086-CR and filed a brief
also due on January 12, 2015,
Donny Joe Curry v. State Appellate Cause numbers 06-14-00139-CR thru
06-14-00142-CR and filed a brief on January 20, 2015.
AND
Grubbs v. State Appellate Cause numbers 06-14-00116-CR &
06-14-00117-CR and is awaiting the Reporter’s record.
Counsel prepared for and represented his clients in an Adversarial
hearings in Hunt County Child Protection Court for Northeast Texas #2 on January
23, 2014 in nine separate cases.
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,
Jason A. Duff
2615 Lee St
P.O. Box 11
Greenville, TX 75403
Tel: 903.455.1991
Fax: 903.455.1417
By: /s/ Jason A. Duff
Jason A. Duff
State Bar No. 24059696
jasonaduff@hotmail.com
Attorney for Willie Frank Jackson
CERTIFICATE OF SERVICE
This is to certify that on January 28, 2014, a true and correct copy of the above
and foregoing document was served on the District Attorney's Office, Hunt County,
by electronic filing system.
/s/ Jason A. Duff
Jason A. Duff