ACCEPTED
06-16-00054-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
6/30/2016 11:49:06 AM
DEBBIE AUTREY
CLERK
NO. 06-16-00054-CR
STATE OF TEXAS § IN THE
FILED IN
§ 6th COURT OF APPEALS
VS. § 6TH COURT TEXARKANA, TEXAS
§ 6/30/2016 11:49:06 AM
JOSEPH EMMANUEL WATKINS § OF APPEALS DEBBIE AUTREY
Clerk
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes JOSEPH EMMANUEL WATKINS, Appellant in the above styled and
numbered cause, and 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 13TH Judicial District Court of Navarro County,
Texas.
2. The case below was styled the STATE OF TEXAS vs. JOSEPH EMMANUEL
WATKINS, and numbered D34,763-CR.
3. Appellant was convicted of Theft Over $1500.
4. Appellant was assessed a sentence of 13 months TDC on 2/12/16.
5. Notice of appeal was given on 3/2/16.
6. The clerk's record was filed on 6/14/16; the reporter's record was filed on 6/14/16.
7. The appellate brief is due on 7/14/16.
8. Appellant requests an extension of time of 30 days from the due date, i.e. 8/14/16.
9. No previous extensions to file the brief has been received in this cause.
10. Defendant is currently incarcerated.
11. Appellant relies on the following facts as good cause for the requested extension:
Appellant’s Counsel is self-employed and a sole practitioner. Due to counsel’s case load
and other work and personal obligations, counsel did not have adequate time to research and
prepare the issues in this case within the 30 day period. Counsel was working on two other
briefs being filed with the courts this week including Ipina v. State, 10-16-00052, and Crenshaw
v. State, 06-16-00061. Counsel has one other brief due in this Court in Liberto v. State,
06-16-00063. Counsel will be out of the country from July 1 – July 18th, 2016.
WHEREFORE, PREMISES CONSIDERED, 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,
Damara H. Watkins
Attorney at Law
1541 Princeton Dr.
Corsicana, TX 75110
Tel: (903) 641-2595
Fax: (903) 872-6456
By: /s/
Damara H. Watkins
State Bar No. 00787740
Attorney for JOSEPH EMMANUEL
WATKINS
CERTIFICATE OF SERVICE
This is to certify that on June 29, 2016, a true and correct copy of the above and foregoing
document was served on the District Attorney's Office, Navarro County, Navarro County
Courthouse, 300 W. 3rd Ave., Corsicana, Texas, by electronic service.
/s/
Damara H. Watkins
Joseph Emmanuel Watkins v. State
Combined Opinion