Casey Michael Rhynes v. State ( 2018 )

ACCEPTED
09-17-00440-CR
NINTH COURT OF APPEALS
BEAUMONT, TEXAS
3/27/2018 8:54 PM
CAROL ANNE HARLEY
CLERK
CASE NOs. 09-17-00440-CR,
09-17-00441-CR, 09-17-00442-CR, 09-17-00443-CR
FILED IN
9th COURT OF APPEALS
CASEY MICHAEL RHYNES § IN THE COURT OF APPEALS
BEAUMONT, TEXAS
§ 3/27/2018 8:54:30 PM
v. § 9th DISTRICT
CAROL ANNE HARLEY
Clerk
§
THE STATE OF TEXAS § BEAUMONT, TEXAS
MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
CASEY MICHAEL RHYNES, Appellant in the above styled and
numbered case, 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 359th Judicial District Court
of Montgomery County, Texas.
2. The case below was styled The State of Texas vs. Casey
Michael Rhynes, and numbered 15-05-05331-CR counts I, II, III, and
IV.
3. Appellant was convicted of the offenses of aggravated
assault against a public servant, two counts of aggravated assault with
a deadly weapon, and evading arrest or detention with a vehicle.
CASEY MICHAEL RHYNES V. THE STATE OF TEXAS
MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF
Page 1 of 4
4. On October 27, 2017, Appellant was assessed a sentence of
fifty years confinement in the Texas Department of Criminal Justice
Institutional Division.
5. Notice of appeal was given on November 16, 2017.
6. The Clerk’s Record was filed on February 26, 2018. The
Reporter’s Record was filed on January 14, 2018.
7. The appellate brief is presently due on March 28, 2018.
8. Appellant requests an extension of time of 30 days from the
present date, i.e. April 27, 2018.
9. No extensions to file the brief have been received in this
cause.
10. Appellant is currently incarcerated.
11. Appellant relies on the following facts as good cause for the
requested extension.
Counsel has been preparing for trial in Cause No. 17-
322588, the State of Texas vs. Austin Scott Moore, which
was set for trial in the County Court at Law No. 1 of
Montgomery County, on April 2, 2018, and was resolved with
an agreed plea of guilty on March 20, 2018.
CASEY MICHAEL RHYNES V. THE STATE OF TEXAS
MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF
Page 2 of 4
Counsel has been preparing for trial in Cause No.
17-324419, the State of Texas vs. Taylor Ann Sterling, which
was set for trial in the County Court at Law No. 1 of
Montgomery County, on March 12, 2018, and was resolved
in an agreed plea of guilty on the trial date.
Counsel was engaged to apply for a determination of
heirship and for letters of administration in the Estate of
Barbara Ann Kmiecik, in Cause No. 465569, which was filed
in the Probate Court No. 3 of Harris County, on March 23,
2018.
CASEY MICHAEL RHYNES PRAYS that the Court grant this
Motion to Extend Time to File Appellant’s Brief.
Respectfully submitted,
Matt Brown
Attorney at Law
332 North Main Street
Conroe, Texas 77301
832-754-7538
936-494-1233 facsimile
matt@pmbrownlaw.com
By:
CASEY MICHAEL RHYNES V. THE STATE OF TEXAS
MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF
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Matt Brown
State Bar No. 24048367
Attorney for Casey Michael Rhynes
CERTIFICATE OF SERVICE
This is to certify that on March 27, 2018, a true and correct copy of
the above and foregoing document was served on the Montgomery
County District Attorney’s Office via the electronic filing manager.
Matt Brown
CASEY MICHAEL RHYNES V. THE STATE OF TEXAS
MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF
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