ACCEPTED
06-14-00192-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
4/14/2015 8:30:47 PM
DEBBIE AUTREY
CLERK
IN THE COURT OF APPEALS
Sixth Appellate District
State of Texas FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
REGINALD REECE, 4/15/2015 8:14:00 AM
Appellant DEBBIE AUTREY
Clerk
v. NO. 06-14-00192-CR
Trial Court #11F0746-202
STATE OF TEXAS,
Appellee
SECOND 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:
I.
A. This case is pending from the 202nd 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 15, 2015.
F. Appellant requests an extension of the filing of Appellant’s Brief Ten (10)
days, making the Appellant’s Brief due on April 25, 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.
Additionally, Appellant’s attorney is appellate counsel for Kevin Fahrni,
currently pending before this Court, in cause number 06-14-00148CR styled,
“Kevin Fahrni v. State of Texas”. Counsel was granted an extension of time
to file the brief in that case to allow the Court Reporter to file an omission
from the record, said brief is currently due April 16, 2015.
H. There has been one previous request for extension 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 he has no
2
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.
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
3