Willie Frank Jackson v. State

ACCEPTED 06-14-00097-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/29/2014 3:43:27 PM DEBBIE AUTREY CLERK NO. 06-14-00097-CR FILED IN 6th COURT OF APPEALS STATE OF TEXAS § IN THE TEXARKANA, TEXAS § 12/29/2014 3:43:27 PM VS. § 6th COURT DEBBIE AUTREY § Clerk WILLIE FRANK JACKSON § OF APPEALS MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Willie Frank Jackson, 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 354TH Judicial District Court of Hunt County, Texas. 2. The case below was styled the STATE OF TEXAS vs. Willie Frank Jackson, and numbered 29,295. 3. Appellant was convicted of Aggravated Robbery, with a Deadly Weapon. 4. Appellant was assessed a sentence of 90 years on May 14, 2014. 5. Notice of appeal was given on May 14, 2014. 6. The clerk's record was filed on September 10, 2014; the reporter's record was filed on November 25, 2014. 7. The appellate brief is presently due on December 29, 2014. 8. Appellant requests an extension of time of 30 days from the present date. 9. No extension 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 attorney, Jason A. Duff has begun a review the several volumes in the reporters record as well as the clerks record the record; but, Appellant’s counsel requests additional time to sufficiently develop the arguments material to the brief. Additionally, Counsel was on vacation from the afternoon of December 24, 2014 through December 28, 2014. Counsel is also appointed in: Garza v. State Appellate Cause numbers 06-14-00088-CR through 06-14-00093, and filed multiple briefs relating to that case December 22, 2014, Counsel is appointed in Semaj Milan Yrnah Smith v. State, Appellate Cause No. 06-14-00158-CR and filed a brief on December 23, 2014, Young v. State Appellate Cause number 06-14-00086-CR with a brief also due on December 29, 2014, Donny Joe Curry v. State Appellate Cause numbers 06-14-00139-CR thru 06-14-00142-CR with a brief due December 29, 2014. Bennett v. State Cause number 06-14-00050-CR where Appellant’s attorney filed a brief on November 17, 2014 and is awaiting Appellee’s brief, AND Grubbs v. State Appellate Cause numbers 06-14-00116-CR & 06-14-00117-CR and is awaiting the Reporter’s record. Appellant counsel’s represented his client at trial in Cause No. CC1400383 Jim Lee Odom v. Troy Morrison in County Court at Law No. 2 of Hunt County Texas on December 16, 2014 Then counsel participated settlement conferences in Cause No. 80,433 ITIO of L.W. and Cause No. 80219, ITIO M.S. E.S and B.M. on December 2, 2014. After the parties failed to reach a settlement in Cause No. 80219, ITIO M.S. E.S and B.M. on December 2, 2014, the trial court ordered the parties back to another conference on December 23, 2014. Counsel prepared for and represented his clients in an Adversarial hearings in Hunt County Child Protection Court for Northeast Texas #2 on December 3, 2014 in Cause No. 81,304 In the Interest of TH & Z.H., Children, as well as a Final Hearing in Cause No. 80,139 In the Interest of D.B., a Child in the 196th Judicial District among several others. Counsel prepared for and represented his clients in an Adversarial hearing in Cause No. 81,304 In the Interest of T.H. &Z.H., Children on December 18, 2014. 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, Jason A. Duff 2615 Lee St P.O. Box 11 Greenville, TX 75403 Tel: 903.455.1991 Fax: 903.455.1417 By: /s/ Jason A. Duff Jason A. Duff State Bar No. 24059696 jasonaduff@hotmail.com Attorney for Willie Frank Jackson CERTIFICATE OF SERVICE This is to certify that on December 29, 2014, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Hunt County, by electronic filing system. /s/ Jason A. Duff Jason A. Duff