Marshall Deshun Parker v. State

ACCEPTED 06-14-00237-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 2/23/2015 4:16:50 PM DEBBIE AUTREY CLERK Cause No. 06-14-00237-CR MARSHALL DESHUN PARKER § IN THE COURT OF FILED IN 6th COURT OF APPEALS VS. § APPEALS, SIXTH DISTRICT TEXARKANA, TEXAS 2/24/2015 12:06:00 PM THE STATE OF TEXAS § STATE OF TEXAS DEBBIE AUTREY Clerk APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLATE BRIEF TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: Comes now MARSHALL DESHUN PARKER, Appellant, and files this motion for an extension of 30 days in which to file the appellate brief. In support of this motion, appellant shows the court the following: I. On September 16, 2014, the appellant was sentenced in the trial court proceeding from which this appeal is made. II. The deadline for filing the appellate brief is February 25, 2015. The appellant has requested no extensions prior to this request. III. Appellant's request for an extension is based upon the following facts: Undersigned counsel only received the reporter’s record in this case by e-mail on February 5, 2015. During the time since then, undersigned counsel for the Appellant had to finalize a brief for this court in Cause No. 06-14-00102-CR, Tyrell Smith v. State of Texas, and has otherwise been wholly occupied with preparation for a jury trial in Harrison County District Court Cause No. 14-0029X, styled “State of Texas v. Brad Dunn,” in which the Defendant in that cause is charged with the offense of murder. Trial in State v. Dunn begins Monday March 2, 2015, and promises to last for the entire week. IV. Undersigned counsel understands that requests for extensions of time are not favored, but given the shorter amount of time that the reporter’s record has been available, and given the undersigned’s unusually crowded calendar during the remaining time, the undersigned finds it necessary to request an extension of thirty (30) days to complete his duties to Appellant. WHEREFORE, appellant prays the court grant this motion and extend the deadline for filing the appellate brief to March 25, 2015. RESPECTFULLY SUBMITTED, SCOTT RECTENWALD 110 W. FANNIN Marshall, Texas 75670 (903) 938-3300 (903) 938-3310 FAX /S/ Scott Rectenwald Scott Rectenwald SBOT # 00794510 Attorney for Appellant Certificate of Service The undersigned hereby certifies that a true and correct copy of the foregoing motion was delivered to the office of the Harrison County District Attorney on February 23, 2015. /S/ Scott Rectenwald