Timothy Paul Bates v. State

ACCEPTED
06-14-00105-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
2/2/2015 12:54:47 PM
DEBBIE AUTREY
CLERK
NO. 6-14-00105CR
FILED IN
6th COURT OF APPEALS
STATE OF TEXAS § IN THE COURT TEXARKANA, TEXAS
2/5/2015 10:28:00 AM
§
DEBBIE AUTREY
Clerk
vs. § OF APPEALS
§
TIMOTHY BATES § SIXTH APPELATE DISTRICT
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Timothy Bates, 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 County Court at Law No. 2, Hunt County,
Texas;
2. The case below was styled State of Texas vs. Timothy Bates, Cause
Number CR1301437.
3. Appellant was convicted of Driving While Intoxicated.
4. Appellant was sentenced to 180 days in jail probated for two years and a
$400 fine.
5. Notice of Appeal was given on June 12, 2014.
6. The Clerk's record was filed on July 7, 2014; The Reporter's record was
filed on November 18, 2014.
7. Appellant's brief is currently due on January 21, 2014
8. Appellant requests an extension of time so that this brief is accepted the
day of submission.
9. No extension has previously been requested in this case.
10. Appellant is not currently incarcerated.
11. 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 became very ill with infectious colitis which required two separate hospital stays for
treatment. Additionally, the Thanksgiving holiday fell between the time of receiving the record
and the due date of Appellant's 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 January 7, 2015, a true and correct copy of the above and
foregoing document was served on the Hunt County Attorney's Office, by hand delivery.
Jessica Edwards