ACCEPTED
061400212CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
4/8/2015 8:15:26 AM
DEBBIE AUTREY
CLERK
NO. 06-14-00212-CR
FILED IN
TERRY EUGENE GLENN, Jr. IN APPEALS
OF COURT
THE COURT 6th OF APPEALS
TEXARKANA, TEXAS
VS. 4/8/2015
SIXTH APPELLATE 9:00:00 AM
DISTRICT
DEBBIE AUTREY
THE STATE OF TEXAS STATE OF TEXAS Clerk
INOTION TO EXTEND TIIIE TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT'
Now comes Terry Glenn, 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 71st Judicial District Court of Harrison
County, Texas.
2. The case below was styled the STATE OF TEXAS vs, Ter Eu ene
Glenn Jr. , and numbered 12-0455X.
3. Appellant was convicted of possession of a controlled substance.
4. Appellant was assessed a sentence of 15 years on October 8, 2014.
5. Notice of appeal was given on December 2, 2014.
6. The clerk's record was filed on December 15, 2014; the reporter's record
was filed on March 8, 2015.
7. The appellate brief is presently due on April 8, 2015.
8. Appellant requests an extension of time of 20 days from the present date,
i.e. April 28, 2015.
9. No previous request for an extension 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:
The reporter's record was filed on March 8, 2014. Since receiving the record,
Appellant's attorney, Laura M. Carpenter, has been called and tried three criminal jury
trials. As such, additional time is requested to file Appellant's brief.
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,
LAURA M CARPENTER PLLC
P.O. Box 8286
Marshall, TX 75671
Tel: (903) 938-7440
Fax: (903) 938-3008
By
aura M. Carpente
State Bar No. 08618050
carpenterlaw1 23@sbcglobal. net
Attorney for Terry Eugene Glenn, Jr.
CERTIFICATE OF SERVICE
This is to certify that on April 8, 2015, a true and correct copy of the above and
foregoing document was served on the District Attorney's Office, Harrison County, by
electronic service through the Electronic Filing Manager.
L M. Carpenter
STATE OF TEXAS
COUNTY OF HARRISON
AFFIDAVIT
BEFORE ME, the undersigned authority, on this day personally appeared Laura
M, Carpenter, who after being duly sworn stated:
"I am the attorney for the appellant in the above numbered and entitled
cause. I have read the foregoing Motion to Extend Time to File
Appellant's Brief and swear that all of the allegations of fact contained
therein are true and correct. "
ra M, Carpenter
Affiant
SUBSCRIBED AND SWORN TO BEFORE ME on April 8, 2015, to certify which
witness my hand and seal of office,
+»I'~ CRYSTAL GAIL ROSERTS Notary Public, State of Texas
MY COMMISSION EXPIRES
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~ January 5, 2018