Latori Devon Mosley v. State ( 2016 )


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  •                                                                                                     ACCEPTED
    12-16-00115-CR
    TWELFTH COURT OF APPEALS
    TYLER, TEXAS
    9/19/2016 10:14:54 PM
    Pam Estes
    CLERK
    No. 12-16-00115-CR
    LATORI DEVON MOSLEY                         §     IN THE COURT OF APPEALS
    FILED IN
    Appellant                               §                     12th COURT OF APPEALS
    TYLER, TEXAS
    §
    vs.                                         §     12TH   JUDICIAL 9/19/2016
    DISTRICT  10:14:54 PM
    PAM ESTES
    §                              Clerk
    THE STATE OF TEXAS,                         §
    Appellee                                §     AT TYLER, TEXAS
    APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF
    ONE DAY REQUEST
    TO THE HONORABLE COURT:
    Now comes Austin Reeve Jackson, counsel for Appellant in the above entitled and
    numbered cause, and makes this Motion, and for good cause shows the following:
    I.
    Appellant’s brief in this matter is due on 19 September 2016.           Three prior
    extensions have been requested.
    II.
    While working on this case counsel has also been working on approximately 50
    open appellate cases in this and other courts to which he has been appointed by Smith
    County. This has included investigating motions for new trials (looking for and talking
    with potential witnesses, jail and office visits with new appellate appointments, trial court
    appearances for the same), requests for and reviews of reporter’s and clerk’s records,
    research, briefing, review of opinions, investigation of potential PDR issues, etc. While
    not all of these seventy or so cases have required significant attention from counsel
    during this time, many of them have which has resulted in counsel having been able to
    devote the full attention necessary to this case prior to today’s date.
    Because of this, counsel was delayed in completing his brief in this matter.
    II.
    Three prior extensions have been requested and it is respectfully prayed that in the
    interest of justice, the Court grant this motion.
    WHEREFORE, PREMISES CONSIDERED, undersigned counsel respectfully
    prays that, in accordance with the applicable law, the Court grant this Motion and extend
    the date by which to file a brief by one day.
    Respectfully submitted,
    /s/Austin Reeve Jackson
    Texas Bar No. 24046139
    112 East Line, Suite 310
    Tyler, TX 75702
    Telephone: (903) 595-6070
    Facsimile: (866) 387-0152
    CERTIFICATE OF SERVICE
    This is to certify that a true and correct copy of the above and foregoing document
    was served on counsel for the State by efile concurrently with its filing.
    /s/Austin Reeve Jackson
    

Document Info

Docket Number: 12-16-00115-CR

Filed Date: 9/19/2016

Precedential Status: Precedential

Modified Date: 9/22/2016