Vincent Alonzo Corson v. State ( 2015 )

ACCEPTED
03-15-00057-CR
4536626
THIRD COURT OF APPEALS
AUSTIN, TEXAS
3/17/2015 4:44:35 PM
JEFFREY D. KYLE
CLERK
IN THE THIRD COURT OF APPEALS
AUSTIN, TEXAS
FILED IN
3rd COURT OF APPEALS
VINCENT ALONZO CORSON, § AUSTIN, TEXAS
Appellant § 3/17/2015 4:44:35 PM
JEFFREY D. KYLE
§ Clerk
V. §
§ CAUSE NO. 03-15-00057-CR
§ TRIAL COURT NO. 72,780
THE STATE OF TEXAS, §
Appellee §
MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
NOW COMES VINCENT ALONZO CORSON, Appellant in the
above styled and numbered cause, by and through Counsel, and moves this
Court to grant an extension of time to file appellant’s brief, pursuant to Rule
38.6(d) of the Texas Rules of Appellate Procedure, and for good cause
shows the following:
1. This case is on appeal from the 426 th District Court in Bell
County, Texas.
2. The case below is styled The State of Texas v. Vincent Alonzo
Corson, and numbered 72,780
3. Appellant was convicted of burglary of aggravated kidnapping.
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4. Appellant was assessed a sentence of forty years in the
Institutional Division-Texas Department of Criminal Justice on December
17, 2014.
5. Notice of appeal was given on December 30, 2014.
6. The Clerk’s and Reporter’s records were filed on February 13,
2015 and January 27, 2015, respectively.
7. The Appellant’s brief was due on March 16, 2015.
8. Appellant requests an extension of time to file Appellant’s brief of
thirty (30) days or until April 15, 2015.
9. No previous requests for extension to file the brief have been filed
in this cause.
10. Defendant is currently incarcerated.
Appellant relies on the following facts as good cause for the requested
extension: The undersigned has had numerous appellate deadlines in the
Courts of Appeal for the Eleventh and Third Districts and the Court of
Criminal Appeals in the past forty five days, all of which preceded the filing
deadline herein including: filing an Appellant’s Petition for Discretionary
Review in State v. Thornburgh, No. 11-12-00328-CR filed March 2, 2015;
and filing appellant’s briefs in State v. George, No. 03-14-00673-CR filed
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March 11, 2015; and State v. Vidaurri, No. 11-14-00291-CR filed January
20, 1015.
The undersigned, therefore, would request an additional thirty (30)
days to review the record and to perform the necessary legal research for
preparation of the brief herein.
WHEREFORE, 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,
COPELAND LAW FIRM
P.O. Box 399
Cedar Park, TX 78613
Tel: 512-897-8126
Fax: 512-215-8114
Email: ecopeland63@yahoo.com
By: /s/ Erika Copeland
Erika Copeland
State Bar No. 16075250
Attorney for Appellant
CERTIFICATE OF SERVICE, of
COMPLIANCE WITH RULE 9 and of CONFERENCE
This is to certify that on March 17, 2015, a true and correct copy of
the above and foregoing document was served on Henry L. Garza, District
Attorney, Attn: Bob Odom—Appellate Section, P.O. Box 540, Belton,
Texas 76513-0909, that the Motion to Extend Time to File Appellant’s Brief
is in compliance with Rule 9 of the Texas Rules of Appellate Procedure and
that portion which must be included under Rule 9.4(i)(1) contains 525
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words, and that Movant has conferenced with all interested parties this date
concerning the motion and none oppose the motion.
/s/ Erika Copeland
Erika Copeland
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