Luther Karl Ferguson v. State

ACCEPTED 14-14-00885-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 1/16/2015 3:48:02 PM CHRISTOPHER PRINE NO. 14-14-00885-CR CLERK IN THE COURT OF APPEALS FOR THE FOURTEENTH DISTRICT OF TEXAS FILED IN 14th COURT OF APPEALS AT HOUSTON HOUSTON, TEXAS 1/16/2015 3:48:02 PM CHRISTOPHER A. PRINE Clerk LUTHER KARL FERGUSON, Appellant § § vs. § § THE STATE OF TEXAS, Appellee § MOTION FOR EXTENSION OF TIME TO FILE BRIEF ON APPEAL FROM CAUSE NO. 1423099 IN THE 183rd DISTRICT COURT OF HARRIS COUNTY, TEXAS Thomas J. Lewis State Bar No. 12308540 1601 Washington Ave. Houston, Texas 77007 Phone: (713) 256-6779 Fax: (713) 861-2951 E-Mail: tjlaw2@comcast.net ATTORNEY FOR APPELLANT TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW LUTHER KARL FERGUSON, APPELLANT, and moves the Court to extend the time for filing a brief herein, and in support thereof would show as follows: I. Appellant was convicted of the offense of Burglary of a Habitation with Intent to Commit Theft and sentenced on October 20, 2014 to a term of 45 years in prison. II. The brief herein is due on January 14, 2015. Appellant’s counsel is a sole practitioner and is currently preparing briefs on two other cases. Appellant’s counsel is also preparing for three felony jury trials in the months of January and February, 2015. III. Appellant counsel requests an extension of 60 days, making the brief due on March 12, 2015, so the Appellant may receive effective assistance of counsel. WHEREFORE, PREMISES CONSIDERED, Defendant prays this Court to grant this Motion and extend the time for the filing of a brief herein. Respectfully submitted, Thomas J. Lewis State Bar No. 12308540 1602 Washington Ave. Houston, Texas 77007 Phone: (713) 256-6779 Fax: (713) 861-2951 E-Mail: tjlaw2@comcast.net ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE I the undersigned attorney certify that a true copy of the foregoing was served on the District Attorney of Harris County, Texas, by e-mail delivery to Curry_Alan@dao.hctx.net on this the 15th day of January , 2015. ______________ Thomas J. Lewis