Randy Crawford v. State ( 2015 )

ACCEPTED 12-15-00176-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 12/4/2015 11:01:35 AM Pam Estes CLERK ____________________________________________________________ 12-15-00176-CR FILED IN 12th COURT OF APPEALS _____________________________________________________________ TYLER, TEXAS 12/4/2015 11:01:35 AM IN THE COURT OF APPEALS PAM ESTES FOR THE TWELFTH APPELLATE DISTRICT Clerk TYLER, TEXAS _____________________________________________________________ RANDY EARL CRAWFORD v. THE STATE OF TEXAS _____________________________________________________________ APPEAL FROM THE 217TH JUDICIAL DISTRICT COURT OF ANGELINA COUNTY, TEXAS UNAPPOSED MOTION FOR LEAVE TO FILE LATE BRIEF OF APPELLANT RANDY EARL CRAWFORD _____________________________________________________________ Respectfully, Submitted: /S/ John D. Reeves JOHN D. REEVES Attorney at Law 1007 Grant Ave Lufkin, Texas 75901 Phone: (936) 632-1609 Fax: (936) 632-1640 SBOT # 16723000 Email: tessabellus@yahoo.com ATTORNEY FOR APPELLANT IDENTITY OF PARTIES AND COUNSEL Parties: Appellant in Trial Court: Randy Earl Crawford #2010594 8101 F.M 969 Austin, Texas 78724 Trial and Appellate Counsel: Appellant: Trial and Appellate: John D. Reeves Attorney at Law 1007 Grant Ave. Lufkin, Texas 75901 Phone: (936) 632-1609 Fax: (936) 632-1640 SBOT # 16723000 Appellee: April Ayers-Perez Trial Scott Greenbaum Angelina County Dist. Atty Angelina County Dist. Atty P.O. Box 908 P.O. Box 908 Lufkin, Texas 75901 Lufkin, Texas 75901 Phone: 936-632-5090 Phone: 936/ 632-5090 SBOT# 24090075 SBOT# 24043703 TO THE HONORABLE FIRST COURT OF APPEALS: Pursuant to Tex. R. App. P.10.1 and 38.6 (d), the Appellant, Randy Earl Crawford, of Angelina County, files this, his Unopposed Motion for Leave to File Late Brief. Randy Earl Crawford’s brief was due on November 24, 2015. Counsel for Randy Earl Crawford relies on the following reasons, to explain the need for the requested extension. Due continuing health issues, counsel was unable to complete the brief. Counsel has hired an attorney to assist with his caseload during his recuperation and has completed the brief, filed in accompaniment to this Motion. All facts recited in this motion are within the personal knowledge of the counsel signing this motion, PRAYER FOR RELIEF For the reasons set forth above, Appellant requests that this Court grant this Unopposed Motion for Leave to File Late Brief and extend the deadline for filing the Appellant’s Brief up to and including December 4, 2015. Appellant requests all other relief to which he may be entitled. /s/John D. Reeves John D. Reeves Attorney at Law 1007 Grant Street Lufkin, Texas 75901 Phone (936) 632-1609 Fax (936) 632-1640 SBOT # 16723000 ATTORNEY FOR APPELLANT CERTIFICATE OF CONFERENCE Pursuant to Tex. R. App. 10.1 (5), certify that the undersigned conferred with opposing counsel who indicated that she does not oppose this motion. /s/John D. Reeves ___________________________ John D. Reeves CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Appellant’s Motion For Leave to File Late Brief on this 4th day of December, 2015 forwarded to April Ayers-Perez, Assistant District Attorney of Angelina County, aperez@angelinecounty.net, by e-filing. /s/John D. Reeves __________________________ John D. Reeves Attorney for Appellant, Randy Earl Crawford