ACCEPTED 06-15-00168-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/16/2015 3:34:25 PM DEBBIE AUTREY CLERK NO. 06-15-00168-CR IN THE COURT OF APPEALS FILED IN 6th COURT OF APPEALS FOR THE SIXTH APPELLATE DISTRICT TEXARKANA, TEXAS AT TEXARKANA 12/16/2015 3:34:25 PM DEBBIE AUTREY Clerk LEON HILL VS. THE STATE OF TEXAS APPEALED FROM THE 4TH DISTRICT COURT, RUSK COUNTY, TEXAS TRIAL CAUSE NO. CR 14-313 FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF FOR LEON HILL, APPELLANT TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW LEON HILL, and pursuant to Rule 10.5(b), TEX. R. APP. PROC., and pursuant to the extension policies of this Court, makes this request to extend filing the brief in this cause and would show as follows: I. The Official Court Reporter has filed the Reporter’s record with this Honorable Court. The undersigned has received copies of that record as well as the Clerk’s Record. The deadline for filing 1 Appellant’s Brief is on or before December 21, 2015. II. Appellant requests an additional thirty (30) days in which to complete the research and writing necessary for submission of the brief. III. As reasonable explanation for the need for an extension of time Appellant would show as follows: While counsel for Appellant has devoted time to reading the record, research, and drafting the Brief, the Brief is not yet finished. Appellate counsel has also during the past thirty days devoted his time to other matters in his office, including, but not limited to, the following matters: Work on Criminal Appeals Working on briefs in these cases: Casey Jones v. State, No. 06-15-00113-CR Brendan X. Douglas v. State, No. 06-15-00067-CR 2 Preparing and Filing a Petition for Discretionary Review in this case: Derek Clinton Ward v. State, PD-1573-15 Work on Civil Appeals Preparing and filing a Petition for Review in: In the Interest of D.G., K. G., H. M. G., Children, on behalf of Bennie G., Supreme Court of Texas Docket No. 15-0919 Perfecting Appeal in “In the Interest of K.O, A.O. and O.O.” Cause No. 06-15-00100-CV. Probate & Estate Work (All in Gregg County) Cause No. 2014-0317-P In re Estate of Baker: conference with counsel Cause No. 2015-0297-E In re Estate of Roberts: conference with counsel Cause No. 2015-0352-E, In re Guardianship of Tommie Johnson: interview ward, prepare pleadings and report, attend hearing on temporary guardianship Child Protective Services Work (All in Gregg County) CPS conferences, court hearings, correspondence in the following cases: 3 No. 2015-1190-CCL2, “Interest of G. O.” No. 2015-369-DR, “Interest of D. W. and K. W.” No. 2015-2162-DR, “Interest of C. Z. Y.” No. 2015-1171-CCL2, “Interest of C.F.” No. 2013-955-DR, “Interest of A. T.” No. 2014-2343-DR, “Interest of J. L. B.” No. 2014-873-DR, “Interest of J. K. V.” No. 2014-873-DR-1, “Interest of K. V.” Counsel has also spent several hours in conference during each week of the past 30-day period with clients who have consulted with counsel on such diverse areas of law as collections, criminal law, probate, juvenile, and other legal matters. With a grant of an additional thirty days Appellate counsel plans to make substantial progress in further reading of the record and in the writing and research on the brief. IV. There has previously been no motion filed for extension of time, or grants of time extended to Appellant, for the filing of 4 Appellant's brief. WHEREFORE, PREMISES CONSIDERED, LEON HILL, Appellant, respectfully requests that this Honorable Court of Appeals will, upon reviewing this Motion, grant the extension of time for filing Appellant's brief as requested herein, and for such other relief to which Appellant may be entitled. Respectfully submitted, LAW OFFICES OF LEW DUNN _/s/ Lew Dunn_ Lew Dunn Attorney at Law 201 E. Methvin, Suite 102 P.O. Box 2226 Longview, Texas 75606 TEL. 903-757-6711 FAX 903-757-6712 Texas State Bar No. 06244600 ATTORNEY FOR APPELLANT 5 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing “First Motion for Extension of Time to File Brief for Leon Hill, Appellant” has been sent by electronic transmission to the following on this 16th day of December, 2015: Hon. Zack Wavrusa, Assistant Criminal District Attorney, Rusk County, Texas, at his e-mail address: zwavrusa@co.rusk.tx.us. __/S/ Hough-Lewis Dunn Hough-Lewis (“Lew”) Dunn 6