Stanford Dewayne Jones Sr. v. State

ACCEPTED 12-15-00157-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 8/12/2015 2:51:29 PM CATHY LUSK CLERK NO. 12-15-00157-CR ON APPEAL FROM THE 159TH JUDICIAL DISTRICT COURTFILED IN ANGELINA COUNTY, TEXAS 12th COURT OF APPEALS TYLER, TEXAS CAUSE NO. 2013-0744 8/12/2015 2:51:29 PM CATHY S. LUSK TH Clerk STANFORD JONES, JR. § IN THE 12 COURT OF APPEALS § § OF vs. § § STATE OF TEXAS § TYLER, TEXAS MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Stanford Jones, Sr., 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 217th District Court of Angelina County, Texas. 2. The case below was styled the STATE OF TEXAS vs. Stanford Jones, Sr., and numbered 2013-0744. Appellant was convicted of Arson. 4. Appellant was assessed a sentence of Twenty (20) years in Texas Department of Criminal Justice Institutional Division on May 14, 2015. 5. Notice of appeal was given on June 10, 2015. 6. The clerk's record was filed on July 10, 2015; the reporter's record was filed on June 29, 2015. 7. The appellate brief was presently due on August 12, 2015. 8. Appellant requests an extension of time of thirty (30) days from the current due date. 9. No extensions to file the brief have 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 ten separate briefs due in the 12th Court of Appeals and the 9th Court of Appeals, which include four due in to the this court in the month of August. Due to the time required to review records of each appeal, counsel is requesting an extension of thirty 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 not 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 12th day of August, 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, Stanford Jones, Sr.