Mark Eugene Engle v. State

ACCEPTED
06-14-00239-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
7/1/2015 5:11:31 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00239-CR
FILED IN
6th COURT OF APPEALS
STATE OF TEXAS § IN THE TEXARKANA, TEXAS
§ 7/1/2015 5:11:31 PM
VS. § 6th COURT DEBBIE AUTREY
§ Clerk
MARK EUGENE ENGLE § OF APPEALS
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF, 2ND
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Mark Eugene Engle, 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. Mark Eugene
Engle, and numbered 29,110.
3. Appellant was convicted of Manufacturing and Delivery of a
Controlled Substance Penalty Group 1 More than Four Grams but less than 200
Grams.
4. Appellant was assessed a sentence of Life on October 1, 2014.
5. Notice of appeal was given on October 3, 2014.
6. The clerk's record was filed on February 5, 2015; the reporter's record
was filed on May 1, 2015.
7. The appellate brief is presently due on July 1, 2015.
8. Appellant requests an extension of time of 30 days from the present
date, i.e. July 31, 2015.
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.
Counsel is also appointed in:
James Wayne Walsh v. The State of Texas, Appellate Case Number: 06-14-
00059-CR with a brief Due also on July 1, 2015.
Shahid Karriem Ansari, III. v. The State of Texas, Appellate Case Number:
06-14-00220-CR with a brief Due on July 22, 2015.
Pamela Diane Contreras v. The State of Texas, Appellate Case Number: 05-
15-00544-CR.
Charles Francis Williams v. The State of Texas, Appellate Cause Numbers:
06-15-00030-CR and 06-15-00031.
Counsel prepared for and represented his client in for a Temporary
Restraining Order Hearing June 18, 2015 Cause No. 76,055 in the 354th Judicial
District of Hunt County.
Counsel prepared for and represented his client in for a Temporary
Restraining Order Hearing June 30, 2015 Cause No. 82,028 in the 354th Judicial
District of Hunt County.
Counsel prepared for and represented his clients for a Final Trial of two
related Termination of Parental rights cases in In the Interest of J.N. and J.N. in
Cause No 81,156 in the 196th District Court and In the Interest of J.F., J.L and J.N.
in Cause No 80,884 in the 196th District Court on May 28, 2015 which was
continued and contested for the entire day of June 19, 2015.
Counsel prepared for and represented his clients in an Adversarial hearings
in Hunt County Child Protection Court for Northeast Texas #2 on June 26, 2015,
which was not completed until after 5 pm and on July 1, 2015 in several 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 75069
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 Mark Eugene Engle
CERTIFICATE OF SERVICE
This is to certify that on July 1, 2015, a true and correct copy of the above
and foregoing document was served on the District Attorney's Office, Hunt
County, by electronic service through the Electronic Filing Manager.
/s/ Jason A. Duff
Jason A. Duff