Larry Dewayne Garrett v. State

ACCEPTED 03-14-00138-CR 3689611 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/7/2015 6:15:29 PM JEFFREY D. KYLE CLERK NO. 03-14-00138-CR STATE OF TEXAS § IN THE FILED IN § 3rd COURT OF APPEALS VS . § AUSTIN, THIRDTEXAS COURT § 1/7/2015 6:15:29 PM LARRY DEWAYNE GARRETT § JEFFREY D. KYLE OF APPEALS Clerk MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: COMES NOW LARRY DEWAYNE GARRETT, 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(d) , in compliance with Ru le 10.5(b), of the Texas Rules of Appellate Procedure, and for good ca use shows the following : 1. This case is on appeal from the County Court at Law Number 2&3 of Bell County, Texas. 2. The case below was styled the State of Texas vs. LARRY DEWA YNE GARRETT, and was numbered 2C1307176 . 3. Appellant was convicted of Violation of Protective Order. 4. Notice of appeal was given on March 6, 2014 . 6. The clerk's record was filed on April16 , 2014; the reporter's record was filed on August 26 , 2014 7. The appellate brief is presently due on January 5, 2015 . 8. Appellant requests an extension of time of 100 days from the original due date; i.e. until April 15, 2015 9. Previous extensions have been requested or granted for the filing of Appellant's brief in this cause . 10. Defendant is not currently incarcerated . 11 . Appellant relies on the following facts as good cause for the requested extension: Counsel for Appellant is conducting a supplemental investigation into the facts and law surrounding the case. The complete reporte r's record in this case has not been filed as of January 5, 2015. The record should be filed soon , as a resu lt, counsel has not had an opp ortunity to adequately review the record from the cou rt below and prepare a completed brief, though counsel has begun the process and expects to be completed with Appellant's brief very soon . WHEREFORE , PREMISES CONSIDERED, Appellant prays that th is 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 , THE LAW OFFICES OF MICHAEL F. W HITE, P.C. 100 Kasberg Drive Suite A Temple, TX 76502 Tel : (2 54) 770-3388 Fax: (254) 770-0883 By·~ : ~====~==~---------­ Michael F. White State Bar No. 00785231 lawyer@vvm .com CERTIFICATE OF SERVICE This is to certify that on January 7, 2015, a true and correct copy of the above and foregoing document was served on the County Attorney, Bell County, Texas Michael F. White .., STATE OF TEXAS § § COU NTY OF BELL § AFFIDAVIT BEFORE ME, the undersigned authority, on this day personally appeared Jeffrey D. Parker, who after being duly sworn stated : "I am the attorney for the appellant in the above numbered and entitled cause. I have read the foregoing Motion To Extend Time to File Appellant's Brief and swear that all of the allegations of fact conta ined therein are true and correct. " r---- -- Michael F. White Affiant ,- 715 SUBSCRIBED AND SWORN TO BEFORE ME on , to certify which witness my hand and seal of office. t ......... ti!JJ LLILLl>sJ aJtL /{VltlUfitgV(_/ (! J(:t__; ~\ DANIELLE DIANE KNEESE-BURGAN Notary Public, State of Texas ' ..~ _:' ~ MY COMMISSION EXPIRES ·· .:,.... ;;·~r L..- .•cr:;.... July 1st 201s .., _)