ACCEPTED
06-15-00036-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
6/12/2015 9:39:08 AM
DEBBIE AUTREY
CLERK
FOR THE SIXTH COURT OF APPEALS
AT TEXARKANA, TEXAS
FILED IN
6th COURT OF APPEALS
QUINTON JACKSON ' TEXARKANA, TEXAS
Appellant 6/12/2015 9:39:08 AM
DEBBIE AUTREY
V. ' CASE NO. Clerk
06-15-00036-CR
TRIAL COURT NO. 42425-B
THE STATE OF TEXAS
Appellee '
MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT=S BRIEF
TO THE HONORABLE COURT OF APPEALS:
NOW COMES, QUINTON JACKSON, the Appellant herein, and moves the Court for an
extension of time to file Appellant=s Brief in this cause, pursuant to Rules 38.6 and 10.5 (b) of
the Texas Rules of Appellate Procedure, and in support thereof would show the Court as follows:
I.
The Appellant in this cause was convicted in the 124th District Court, Gregg County,
Texas in cause number 42425-B for the offense of Injury to a Child, Elderly or Disabled
Individual. On November 24, 2014, punishment was assessed at Ten years in the Texas
Department of Criminal Justice-Institutional Division.
II.
The Reporter=s record was filed on May 13, 2015. The Appellant=s Brief is due on or
about June 12, 2015.
III.
The Appellant hereby requests an extension of time to file Appellant=s Brief.
The undersigned counsel has been unable to devote sufficient time to the review of the
record, research and preparation of Appellant=s Brief for the following good and sufficient
reasons:
1. Defense Counsel has been involved in a very busy trial and appellate schedule in both
state and federal courts at various stages of litigation.
2. Counsel underwent surgery at the Harvard Medical School in Boston
Massachusetts and has been diagnosed with complications. Counsel was scheduled for a follow
up doctor’s appointment on June 4, 2015 and continues to be under a doctor’s care.
WHEREFORE, PREMISES CONSIDERED, the undersigned counsel, on behalf of
Appellant, respectfully prays that this Honorable Court extend the time for filing Appellant=s
Brief for an additional thirty (30) days, to July 13, 2015.
RESPECTFULLY SUBMITTED,
__/s/ Clement Dunn_______
Attorney for Appellant
140 E. Tyler Street, Suite 240
Longview, TX 75601
(903) 753-7071 Fax (903) 753-8783
State Bar # 06249300
CERTIFICATE OF SERVICE
As Attorney of Record for Defendant, I do hereby Certify that a true and correct copy of
the above and foregoing document was this date provided to the Attorney for the State.
Date: 06-12-15
__/s/ Clement Dunn_______
Attorney for Appellant
FOR THE SIXTH COURT OF APPEALS
AT TEXARKANA, TEXAS
QUINTON JACKSON '
Appellant
VI. ' CASE NO. 06-15-00036-CR
TRIAL COURT NO. 42425-B
THE STATE OF TEXAS
Appellee '
ORDER
BE IT REMEMBERED, that on the _____ day of __________________, 2015, came
on to be considered the above and foregoing Motion for Extension of Time to File Appellant=s
Brief. After consideration of the same, it is the opinion of the Court that Appellant=s Motion be:
( ) GRANTED, and the present cause is hereby extended until _________________,
2015.
( ) DENIED, to which ruling the Appellant excepts.
( ) SET FOR HEARING ON THE _____ day of __________________, 2015, at
_____ o=clock_____.
SIGNED:
_____________________________
JUDGE PRESIDING
Quinton Jackson v. State
Combined Opinion