Dequisha Jackson v. State

ACCEPTED 12-15-00003-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 6/24/2015 11:01:10 AM CATHY LUSK CLERK NO. 12-15-00003-CR ON APPEAL FROM THE 159TH JUDICIAL DISTRICT COURTFILED IN ANGELINA COUNTY, TEXAS 12th COURT OF APPEALS TYLER, TEXAS CAUSE NO. 2013-0731 6/24/2015 11:01:10 AM CATHY S. LUSK TH Clerk DEQUISHA JACKSON § IN THE 12 COURT OF APPEALS § § OF vs. § § STATE OF TEXAS § TYLER, TEXAS SECOND MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Dequisha Jackson, 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 159th District Court of Angelina County, Texas. 2. The case below was styled the STATE OF TEXAS vs. Dequisha Jackson, and numbered 2013-0731. Appellant was convicted of Manslaughter. 4. Appellant was assessed a sentence of Fifteen (15) years in Texas Department of Criminal Justice Institutional Division on December 17, 2015. 5. Notice of appeal was given on December 30, 2015. 6. The clerk's record was filed on February 17, 2015; the reporter's record was filed on May 21, 2015. 7. The appellate brief was presently due on June 22, 2015. 8. Appellant requests an extension of time of thirty (30) days from the current due date. 9. No extensions to file the brief has been received in this cause. 10. Defendant is currently incarcerated. 11. Appellant relies on the following facts as good cause for the requested extension: Counsel currently has a brief due in the 9th Court of Appeals this week that contains over a thousand pages of transcript. Due to the complex nature of the trial transcripts an additional brief due this week, Counsel will be unable to complete the brief and will need an additional 30 days. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this Motion to Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate. Respectfully submitted: /s/John D. Reeves ____________________ John D. Reeves Attorney at Law 1007 Grant Lufkin, Texas 75901 Phone (936) 632-160 Fax: (936) 632-1640 tessabellus@yahoo.com SBOT # 16723000 Counsel for Appellant CERTIFICATE OF CONFERENCE Pursuant to Tex. R. App. 10.1 (5), certify that I, the undersigned conferred with opposing counsel who is opposed to an extension. /s/John D. Reeves ___________________________ John D. Reeves CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Appellant’s Motion to Extend Time to file Appellant’s Brief on this 24h day of June, 2015 forwarded to State’s Attorney, April Ayers-Perez, Angelina County, by electronic service at aprerez@angelinacounty.net. /s/John D. Reeves __________________________ John D. Reeves Attorney for Appellant, Dequisha Jackson