ACCEPTED
06-14-00115-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
1/29/2015 10:52:54 AM
DEBBIE AUTREY
CLERK
NO. 06-14-00115-CR
IN THE COURT OF APPEALS FILED IN
FOR THE SIXTH APPELLATE DISTRICT6thTEXARKANA,
COURT OF APPEALS
TEXAS
AT TEXARKANA 1/29/2015 10:52:54 AM
DEBBIE AUTREY
Clerk
CORDERO BROWN
VS.
THE STATE OF TEXAS
APPEALED FROM THE 124TH DISTRICT COURT, GREGG COUNTY
TRIAL CAUSE NO. 42,258-B
APPELLANT’S FIRST MOTION
FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW CORDERO BROWN, Appellant, and respectfully
submits this, his First Motion for Extension of Time to file his Brief herein, and
pursuant to Rule 10.5(b), TEX.R.APP.P., and pursuant to the extension policies of
this Court, makes this request to extend time for filing the brief in this cause and
would show as follows:
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I
The Official Court Reporter has filed the Reporter's Record with this
Honorable Court. The undersigned counsel has received the copies of the Reporter’s
Record and Clerk’s Record. The deadline for filing Appellant’s brief is due on or
before February 2, 2015.
II.
Appellant requests an additional thirty (30) days in which to complete the
research and writing necessary for submission of the brief.
III.
As reasonable explanation for the need for an extension Appellant would show
as follows:
1. While Counsel for Appellant has devoted time to reading the
record, research, and drafting the Brief, the Brief is not yet finished.
2. Appellate counsel has also, during the past 30 days, devoted his time
to other matters in his office, including, but not limited to, representation in
the following matters:
A. Criminal Appeals
State v. Karl Houlditch, Cause No. 13,0263X, 71st District Court of Harrison
County: preparing for and presenting Motion for New Trial on January 25, 2015;
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plus additional memorandum of law to trial court
Tommy Scott Thomas, Cause No. PD-0057-15, drafting and filing Petition
for Discretionary review in Court of Criminal Appeals of Texas
Esaw Lampkin, Cause No. 06-14-00024-CR; correspondence with client
Kadeem Ray, Cause No. 06-14-00106-CR; correspondence with client
Cinque Ross, Cause No.s 06-14-00157-CR and 06-14-00206-CR;
correspondence with client
B. Probate & Estate Work
Estate of Harriet Hall, initial conferences on probate of will; drafting
application and other documents, with intent to file week of February 2, 2015.
C. Child Protective Services Work
CPS conferences, court hearings, correspondence in the following cases:
No. 2014-873-DR, “Interest of J.V. & K.V.”
No. 2013-955-DR, “Interest of A.T.”
No. 2014-180-DR, “Interest of K.M. & K.J.”
No. 2014-2343-DR, “Interest of J.L.B.”
No. 2014-1891-DR, “Interest of G.L.H.”
No. 2014-1596-DR, “Interest of J. S., S. H., AND R. H.”
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Correspondence in appeal No. 06-14-00087-CV, “In the Interest of
J. M. A. E. W., A Child” pending in this case; reading State’s brief and Guardian Ad
Litem’s brief
D. Civil Litigation
Drafting discovery, motions, getting settings and/or other activities in following:
Cause No. 2014-2434-CCL2, Pope & Turner, Inc. of Overton, vs. John Edward
McDade, Jr., et al, pending in County Court at Law No. 2, Gregg County
Cause No. CV14-1856, Sacor Financial, Inc., etc. vs. Texas Bank & Trust, pending
in 43rd District Court of Parker County, action in garnishment
Counsel has also spent several hours in conference during each week of the
past 30- day period with clients who have consulted with counsel on such diverse
areas of law as collections, criminal law, probate, juvenile, and other legal matters.
With a grant of an additional thirty days Appellate counsel plans to finish
writing the brief and submit it to the Court.
IV.
There has previously been no motion filed for extension of time, or grants of
time extended to Appellant, for the filing of Appellant's brief.
WHEREFORE, PREMISES CONSIDERED, CORDERO BROWN,
Appellant, respectfully requests that this Honorable Court of Appeals will, upon
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reviewing this Motion, grant the extension of time for filing Appellant's brief as
requested herein, and for such other relief to which Appellant may be entitled.
Respectfully submitted,
LAW OFFICES OF LEW DUNN
_/s/ Lew Dunn_
Lew Dunn Attorney at Law
201 E. Methvin, Suite 102
P.O. Box 2226
Longview, Texas 75606
903-757-6711
FAX 903-757-6712
Texas State Bar No. 06244600
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion
was hand-delivered or sent by first class mail or by electronic transmission to
the office of Hon. Zan Colson Brown, Assistant Criminal District Attorney,
Gregg County Courthouse, 101 E. Methvin, Longview, Texas 75601 on this 29
day of January, 2015.
/s/_LewDunn_____________
Lew Dunn
COUNSEL FOR APPELLANT
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Cordero Brown v. State
Combined Opinion