Reginald Reece v. State

ACCEPTED
06-14-00192-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
3/13/2015 10:36:30 AM
DEBBIE AUTREY
CLERK

IN THE COURT OF APPEALS
Sixth Appellate District
State of Texas FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
REGINALD REECE, 3/13/2015 10:36:30 AM
Appellant DEBBIE AUTREY
Clerk
v. NO. 06-14-00192-CR
Trial Court #11F0746-202
STATE OF TEXAS,
Appellee

MOTION FOR EXTENSION
OF TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW Reginald Reece, Appellant, by and through his below

named Attorney and pursuant to Texas Rules of Appellate Procedure, hereby

requests an extension of the time period for the filing of the Appellant’s Brief

and in support of same would show the Court as follows:

A. This case is pending from the 20nd Judicial District Court of Bowie

County, Texas. The date of the Judgment is October 12, 2014, with

sentence being imposed by the trial court on October 12, 2014.

B. The case was styled, “State of Texas v. Reginald Reece, Cause No. 11 F

0746 202.

C. Appellant was convicted of the offense of Theft of less than $1500.00,
With Prior Convictions.

D. Punishment was assessed by the jury to 20 years in the Institutional

Division of the Texas Department of Criminal Justice.

E. The Appellant’s Brief is due to be filed March 16, 2015.

F. Appellant requests an extension of the filing of Appellant’s Brief Forty-

Five (45) days, making the Appellant’s Brief due on April 30, 2015.

G. Appellant’s attorney has been diligent in researching and preparing the

Appellant’s brief for the Court however, due to counsel’s preparation in

a capital murder criminal jury trial styled the State of Arkansas v. Tim

Howard, in the Circuit Court of Little River County, Arkansas, counsel

has had insufficient time to complete Appellant’s brief.

H. There have been no previous requests for extensions in this cause.

I. Counsel for Appellant has contacted the Assistant Criminal District

Attorney for Bowie County, Texas, who is assigned to this matter and

she has no objection to the request of the Appellant.

II.

Appellant’s attorney has been diligent in pursuing this appeal and is not

seeking this extension for the purpose of delay.

2
PRAYER

WHEREFORE, on the basis of the Texas Rules of Appellate Procedure,

Appellant’s attorney respectfully requests this Court to grant the Motion for

Extension of Time for the filing of Appellant’s Brief.

Respectfully submitted,

/s/ Alwin A. Smith
Alwin A. Smith
TBN: 18532200
al@alwinsmith.com
602 Pine Street
Texarkana, Texas 75501
903/792-1608
903/792-0899 Fax

CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing
Motion for Extension of Time to File Appellant’s Brief has been forwarded to
Michael Shepherd, 601 Main Street, Texarkana, Texas, on this the _13th_ day
of March 2015.

/s/Aliwn A. Smith
Alwin A. Smith