Donald Ray Brown v. State

ACCEPTED 06-14-00183-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 5/11/2015 12:00:00 AM DEBBIE AUTREY CLERK IN THE COURT OF APPEALS SIXTH JUDICIAL DISTRICT OF TEXAS AT TEXARKANA FILED IN 6th COURT OF APPEALS DONALD RAY BROWN, TEXARKANA, TEXAS Appellant 5/11/2015 8:13:00 AM DEBBIE AUTREY vs. Appellate Cause Clerk No. 06-14-00183-CR THE STATE OF TEXAS, Appellee APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE BRIEF TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW the Appellant in the above styled and numbered cause and respectfully moves the Court in accordance with Tex. R. App. Pro. Rule 38.6 (d), to extend the time for filing Appellant's Brief in this cause, and in support therefore would respectfully show unto the Court as follows: I. The certified Clerk's Record was timely filed on the 30th day of January, 2015, and the certified Reporter's Record was timely filed on the 8th day of April, 2015. II. The current deadline for filing Appellant's Brief is the 11th day of May, 2015. III. The undersigned attorney has not had sufficient time to prepare Appellant's brief within the currently prescribed time allotted and hereby requests an additional thirty (30) days in which to prepare the brief. More specifically, undersigned attorney has been preparing for pretrial hearings and trial in the following cases: 1 1. United States vs Kevin Bolton, Cause No. 6:14CR60003-001, United States District Court for the Western District of Arkansas, a potential federal death penalty case wherein the undersigned is currently developing the defendant’s mitigation case to be presented to the United States Attorney’s Office for the Western District of Arkansas and to the United States Department of Justice in an effort to avoid authorization to seek the death penalty. IV. Appellant's attorney has not previously requested an extension of time to file the Brief in this cause. WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests this Honorable Court extend the time for filing his brief in this cause until the 11th day of June, 2015. Respectfully submitted, CRAIG L. HENRY Attorney at Law 723 Main Street P.O. Box 3226 Texarkana, Texas 75504-3226 (903) 792-4645 FAX - (903) 792-5073 Lawyrntx@aol.com By/s/ Craig L. Henry Craig L. Henry Arkansas Bar # 90142 Oklahoma Bar # 016779 Texas Bar # 09479260 Attorney for Appellant 2 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Motion has been delivered electronically and via courier to Mr. Jerry Rochelle, Bowie County District Attorney, 601 Main Street, Texarkana, Texas 75501, this 9th day of August, 2015. /s/ Craig L. Henry Craig L. Henry 3