Christopher Wiley v. State

ACCEPTED 12-14-00126-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 1/5/2015 10:05:59 PM CATHY LUSK CLERK No. 12-14-00126-CR CHRISTOPHER WILEY § IN THE COURT OF APPEALS FILED IN Appellant § 12th COURT OF APPEALS TYLER, TEXAS § vs. § 12TH JUDICIAL 1/5/2015 DISTRICT 10:05:59 PM CATHY S. LUSK § Clerk THE STATE OF TEXAS, § Appellee § AT TYLER, TEXAS APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF THREE-DAY REQUEST TO THE HONORABLE COURT: Now comes Austin Reeve Jackson, counsel for Appellant in the above entitled and numbered cause, and makes this Motion, and for good cause shows the following: I. Appellant’s brief in this matter is due on 5 January 2015. One prior extension has been requested. II. While working on this case counsel has also been working on approximately 55 open appellate cases in this and other courts to which he has been appointed by Smith County. This has included investigating motions for new trials (looking for and talking with potential witnesses, jail and office visits with new appellate appointments, trial court appearances for the same), requests for and reviews of reporter’s and clerk’s records, research, briefing, review of opinions, investigation of potential PDR issues, etc. While not all of these seventy or so cases have required significant attention from counsel during this time, many of them have which ahs resulted form counsel having been able to devote the full attention necessary to this case prior to today’s date. II. One prior extensions have been requested and is respectfully prayed that the in the interest of justice, the Court grant this motion. WHEREFORE, PREMISES CONSIDERED, undersigned counsel respectfully prays that, in accordance with the applicable law, the Court grant this Motion and extend the date by which to file a brief by three days. Respectfully submitted, /s/Austin Reeve Jackson Texas Bar No. 24046139 112 East Line, Suite 310 Tyler, TX 75702 Telephone: (903) 595-6070 Facsimile: (866) 387-0152 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing document was served on counsel for the State by facsimile concurrently with its filing. /s/Austin Reeve Jackson