Benny Rivera Rodgers v. State

ACCEPTED 03-14-00398-CR 3911223 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/27/2015 11:07:25 AM JEFFREY D. KYLE CLERK NO. 03-14-00398-CR BENNY RIVERA RODGERS § IN THE FILED IN 3rd COURT OF APPEALS § AUSTIN, TEXAS VS. § THIRD COURT1/27/2015 11:07:25 AM § JEFFREY D. KYLE Clerk STATE OF TEXAS § OF APPEALS APPELLANT’S FOURTH MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Benny Rivera Rodgers, Appellant in the above styled and numbered cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the 119th Judicial District Court in Concho County, Texas. 2. The case below was styled the State of Texas vs. Benny Rivera Rodgers and numbered DSM-13-01853. 3. Appellant was convicted of Possession of a Controlled Substance Less than 1 Gram. 4. Appellant was assessed a sentence of 2 years in the Texas Department of Criminal Justice and a $5,000.00 fine on April 30, 2014. 5. Notice of appeal was given May 29, 2014. 6. The clerk's record was filed on July 30, 2014; the reporter's record was filed on July 22, 2014 with exhibits submitted on July 22, 2014. 7. The appellate brief is presently due on January 28, 2015. 8. Appellant requests an extension of time of 10 days from the present date due of January 28, 2015 to February 5, 2015. 9. Three extensions to file the brief have been received in this cause. 10. Appellant is currently in custody. 11. Appellant relies on the following facts as good cause for the requested extension: a. Appellant’s Brief is presently due on January 28, 2015. Counsel did not represent the Appellant at trial. b. Counsel is unable to file Appellant’s Brief that is due on January 28, 2015 because she has completed two briefs that were due prior to this case, and has had an extensive trial docket and has not had sufficient time to review the transcript and exhibits. d. Counsel believes without additional time to prepare said brief appellant will be denied effective assistance of counsel in this matter. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this FOURTH Motion to Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate. Respectfully submitted, AMY HENNINGTON & ASSOCIATES P.C. 125 South Washington Street San Angelo, Texas 76901 Tel: (325) 659-8929 Fax: (325) 482-8064 By:/S/Amy Hennington State Bar No. 00790866 Attorney for Benny Rivera Rodgers CERTIFICATE OF SERVICE This is to certify that on January 27, 2015, a true and correct copy of the above and foregoing document was served on the 119th Judicial District Attorney's Office, by facsimile transmission. /S/ Amy Hennington Amy Hennington