ACCEPTED
05-14-00806-cr
FIFTH COURT OF APPEALS
DALLAS, TEXAS
1/28/2015 9:48:39 PM
LISA MATZ
CLERK
No. 05-14-00806-CR
FILED IN
5th COURT OF APPEALS
Ronnie Heath § In the Court of AppealsDALLAS, TEXAS
1/28/2015 9:48:39 PM
vs. § For the Fifth District LISA MATZ
Clerk
The State of Texas § of Texas at Dallas
Second Motion To Extend Time For Filing Appellant's Brief
Appellant, by and through his attorney of record, respectfully requests an
extension of time to file his brief. In support Appellant shows:
Appellant was convicted for the offense of theft of aluminum in Cause No.
F14-53600-H in the Criminal District Court of Dallas County, Texas. The judgment
was dated June 12, 2014. Notice of Appeal was filed on June 12, 2014.
The present deadline for filing Appellant's brief was January 19, 2015.
Appellant respectfully requests an extension of time until January 28, 2015 or until
this Court has an opportunity to rule on this motion. One previous extension of time
has been granted. The brief is being tendered with this motion.
Counsel has been attending her daily criminal, CPS and juvenile case docket.
Counsel took several days vacation over the Christmas holidays. Counsel has been
visiting her clients in preparation for bi-yearly hearings pursuant to Chapter 263 of
the Texas Family Code. This required travel throughout the State of Texas. The
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hearings were conducted on January 26, 2015. One of counsel’s clients is a medically
fragile child for whom she had to prepare an emergency Temporary Restraining Order
to prevent him from being moved from his current placement.
In addition, counsel has reviewed the record and filed briefs in the following
cases on the dates indicated:
In the Interest of A.B., et al 05-14-01123-CV December 1, 2014
In the Interest of D.W., et al 14-1018 December 8, 20141
In the Interest of H.F., et al 05-14-01472-CV December 18, 2014
In the Interest of A.B., et al 05-14-01465-CV December 20, 2014
In the Interest of C.L., et al 05-14-01520-CV December 22, 2014
Melquiades Hernandez 05-14-00495-CR January 27, 2015
The first five cases listed were accelerated due to the subject matter:
termination of parental rights.
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A Petition for Review in the Supreme Court of Texas.
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WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests
that the time for filing Appellant's brief be extended to January 28, 2015 or until this
Court has an opportunity to rule on this motion.
Respectfully submitted,
/s/ April E. Smith
Attorney for Appellant
State Bar No. 18532800
P.O. Box 870550
Mesquite, Texas 75187-0550
972-613-5751
FAX: 972-686-4714
april@aesmithlaw.com
CERTIFICATE OF SERVICE
I hereby certify that a copy of this motion has been served via the eFile
Texas.gov service function on Lisa Smith, Acting Chief of the Appellate Section of
the Dallas County Criminal District Attorney’s Office, at lisa.smith@dallascounty.org
on January 28, 2015.
/s/April E. Smith
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Ronnie Heath v. State
Combined Opinion