ACCEPTED
12-14-00335-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
4/9/2015 11:47:02 AM
CATHY LUSK
CLERK
No. 12-14-00335-CR
DONNIE CARR § IN THE COURT OF APPEALS
FILED IN
Appellant § 12th COURT OF APPEALS
TYLER, TEXAS
§
vs. § 12TH JUDICIAL 4/9/2015
DISTRICT 11:47:02 AM
CATHY S. LUSK
§ Clerk
THE STATE OF TEXAS, §
Appellee § AT TYLER, TEXAS
APPELLANT’S MOTION FOR ACCEPTANCE OF LATE BRIEF
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 23 March 2015. No prior extensions
have been requested.
II.
This case presented a potential issue that was unique to counsel and, as a result,
required additional time to research.
Additionally, while working on this case counsel has also been working on
approximately 50 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.
Because of this, counsel was delayed in completing his brief in this matter.
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 accept
the brief filed in today in this matter.
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 efile concurrently with its filing.
/s/Austin Reeve Jackson