Cornell McHenry v. State

ACCEPTED 06-14-00131-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 1/17/2015 9:55:57 AM DEBBIE AUTREY CLERK IN THE COURT OF APPEALS SIXTH APPELLATE DISTRICT OF TEXAS AT TEXARKANA FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 1/17/2015 9:55:57 AM NO: 06-14-00131-CR DEBBIE AUTREY Clerk CORNELL DUPREE MCHENRY, APPELLANT VS. THE STATE OF TEXAS, APPELLEE Appeal from the 202nd District Court Of Bowie County, Texas MOTION FOR LEAVE TO FILE LATE BRIEF, Bart C. Craytor bcraytor@gmail.com Texas Bar No: 24014210 LESHER & McCOY 126 West Second Street Mount Pleasant, Texas 75455 Tel: 903.572.2889 Fax: 866-314-2960 ATTORNEY FOR APPELLANT TO THE HONORABLE JUSTICES OF SAID COURT: COMES NOW the Defendant/Appellant by and through his below named Attorney and for his Motion for Belated Filing of Appellant’s Brief states as follows: I. 1. This case is pending from the 202nd Judicial District of Bowie County, Texas. 2. The case is styled State of Texas v. Cornell McHenry, Cause No. 13F00017-202. 3. Appellant was found guilty to the offense of Possession of a Controlled Substance and sentenced to twenty-five (25) years, in the Institutional Division of the Texas Department of Criminal Justice. 4. Appellant’s Brief was due on December 2, 2014 5. Appellant has now completed his brief and requests leave of this Court for the belated filing of the same. Appellant’s completed brief is filed simultaneously with this Motion. 6. The Brief was not timely prepared in this matter due to the press of the business, both trial and appellate. Additionally there were issues unique and of a first nature to Counsel for Appellant which increased the time necessary for research and added to the complexity of the Brief. Furthermore, Counsel attended continuing education a part of which assisted in preparing the Brief. Respectfully Submitted, Bart C. Craytor LESHER & McCOY 126 West Second Street -2- Mount Pleasant, Texas 75455 Tel: 903.572.2889 Fax: 866.314.2960 e-mail: bcraytor@gmail.com BY: __________________________________ Bart C. Craytor Texas Bar No: 24014210 ATTORNEY FOR APPELLANT -3- CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and forgoing has been served upon the following names and addresses on this 17th day of January, 2015. Mr. Jerry Rochelle Bowie County District Attorney Bowie County Plaza 601 Main Street Texarkana, Texas 75501 Tel: 903.735.4800 Fax: 903.735.4819 ________________________________ Bart C. Craytor -4-