ACCEPTED
12-14-00286-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
3/2/2015 4:24:34 PM
CATHY LUSK
CLERK
No. 12-14-00286-CR
WILLIAM M. SMITH § IN THE COURT OF APPEALS
FILED IN
Appellant § 12th COURT OF APPEALS
TYLER, TEXAS
§
3/2/2015 4:24:34 PM
vs. § 12TH JUDICIAL DISTRICT
CATHY S. LUSK
§ Clerk
THE STATE OF TEXAS, §
Appellee § AT TYLER, TEXAS
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF
THIRTY-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 was due on 15 February 2015. No prior extensions
have 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.
Additionally, in the thirty day period after which the Reporter’s Record was filed
in this case Counsel was preparing for what had been a specially set murder trial that had
been expected to take two weeks and which presented multiple complex issues. This
case, State v. Gage, 007-0957-14, was, however, resolved by plea at the last minute but
not in time to allow counsel sufficient time to devote to this matter the attention it
deserves.
II.
No 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 thirty 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