ACCEPTED
06-16-00067-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
6/30/2016 5:49:53 PM
DEBBIE AUTREY
SIXTH COURT OF APPEALS
CLERK
TEXARKANA, TEXAS
06-16-00067-CR FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
7/1/2016 8:13:00 AM
DEBBIE AUTREY
Clerk
MICHAEL ALAN HODGES
VS.
THE STATE OF TEXAS
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW, Appellant and files this request for an extension of
time to file his brief and would show unto the Court the following:
Court below: 54th District Court
Cause number below: No 2014-1486-C2
Date Petition for Discretionary
Review refused: NA
Present deadline for filing Appellant’s Brief: June 30, 2016
Days requested by this extension: 30 days
Date to which extension is requested: July 30, 2016
Number of extensions previously granted: 1
Hodges, Michael 1
I.
The Appellant’s request is based upon the following reasonable
explanation of the need for additional time, within the personal knowledge
of Charles W. McDonald, the attorney signing this motion, Pursuant to TEX.
R. APP. PROC. 10.5(b), namely:
II.
Counsel requests thirty (30) additional days to complete the brief as
counsel unexpectedly had to file an eighty (80) page summary judgment
response. Counsel assures the Court that this request is not for the sake of
delay. Counsel unfortunately, at times, believes he can get out the quantity
of work today that he could thirty (30) years ago, albeit this is not always an
accurate assessment.
III.
Appellant requests that the Court grant this motion and extend the
time and deadline for the filing of appellant’s brief as asked for, or the Court
grant such additional time as is just and proper, and accordingly, Appellant
so prays.
Hodges, Michael 2
Respectfully submitted,
/s/Charles W. McDonald
Charles W. McDonald
2024 Austin Avenue
Waco, Texas 76701
Phone: (254) 752-9901
Fax: (254) 754-1466
SBOT No. 13538800
Email: ringwraith1cwm@aol.com
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the above and
foregoing instrument was served upon Abelino “Abel” Reyna, McLennan
County Criminal District Attorney, 219 N. Sixth Street, Suite 200, Waco,
Texas 76701-1363, according to rule and law, this 30th day of June, 2016.
/s/Charles W. McDonald
Charles W. McDonald
Hodges, Michael 3