ACCEPTED
12-14-00245-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
1/6/2015 2:49:27 PM
CATHY LUSK
CLERK
DOCKET NO. 12-14-00245-CR
CAUSE NO. 19062
JUSTIN CHRISTIAN § FILED IN
IN THE COURT OF APPEALS
12th COURT OF APPEALS
TYLER, TEXAS
VS. § TWELFTH DISTRICT
1/6/2015 2:49:27 PM
STATE OF TEXAS § CHEROKEE COUNTY, CATHY
TEXAS S. LUSK
Clerk
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes JUSTIN CHRISTIAN, 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 2nd Judicial District Court of Cherokee County,
Texas.
2. The case below was styled the STATE OF TEXAS vs. JUSTIN CHRISTIAN, and
numbered 19062.
3. Appellant was convicted of ASSAULT FAMILY VIOLENCE, IMPEDING
BREATH/CIRCULATION.
4. Appellant was assessed a sentence of 10 years confinement institutional
division, TDCJ on AUGUST 5, 2014.
5. Notice of appeal was given on AUGUST 26, 2014
6. The clerk's record was filed on SEPTEMBER 12, 2014; the reporter's record was
filed in OCTOBER, 2014.
7. The appellate brief is presently due on January 5, 2015.
8. Appellant requests an extension of time of 7 days from the present date, i.e.
January 12, 2015
9. This is the third request for extension to file the brief filed in this cause.
10. Defendant is currently incarcerated.
11. Appellant’s attorney has been unable to complete the brief due to his holiday
schedule and Court appearances.
12. Counsel requests this extension not for the sole purpose of delay but so that
justice may be done.
Motion to Extend Time to File Appellant’s Brief Page 1 of 2
13. Counsel has conferred with the prosecuting attorney who he is in trial with in
the cause referenced above who has indicated he does not object to this motion
and has signed the same.
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,
ALLEN W. ROSS
Attorney at Law
P.O. Box 528
Jacksonville, Texas 75766
903.683-2454 (voice)
866.576-5317 (fax)
allen@arossatty.com
By:____________________________________
ALLEN W. ROSS
State Bar No. 00788324
Attorney for JUSTIN CHRISTIAN
CERTIFICATE OF SERVICE
This is to certify that on January 6, 2015 a true and correct copy of the above
and foregoing document was served on the District Attorney's Office, Cherokee
County, Texas, by facsimile transmission to 903 683 2309.
_______________________________________
ALLEN W. ROSS
Motion to Extend Time to File Appellant’s Brief Page 2 of 2