Roland I. Odom v. State

ACCEPTED 12-15-00151-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 8/24/2015 9:59:47 PM CATHY LUSK CLERK NO. 12-15-00151 ROLAND ODON § IN THE 12TH COURT OF APPEALS § FILED IN V. 12th COURT § TYLER DIVISION TYLER, TEXAS OF APPEALS § 8/24/2015 9:59:47 PM STATE OF TEXAS § STATE OF TEXAS CATHY S. LUSK Clerk APPELLANT'S REQUEST FOR EXTENSION TO FILE BRIEF TO THE HONORABLE COURT OF APPEALS: NOW COMES Appellant before this Court, and Defendant in the Trial Court in Cause Number before the 2nd Judicial District Court, Cherokee County, Texas, and files this his Motion for Extension to File Brief, pursuant to Rules 10.5(b) and 38.6 (d) of the Texas Rules of Appellate Procedure, and for same would show unto the Court as follows, to-wit: I. First Motion: This is Appellant first motion for extension of the deadline for the filing of Appellant’s Brief. II. Original Brief Deadline: Appellant’s Brief was due to be filed on or before August 14, 2015. III. 12th Court Pronouncement of 08-24-15 Deadline: Under cover date about ten days ago, the 12th Court of Appeals advised appellate counsel that Appellant’s brief was overdue and that a motion for extension and/or concomitantly file brief and motion for extension was required. 1 IV. Grounds for Extension: Counsel would shoe that he is a solo practicioner with limited staff, and has recently deal this health issues of his wife and mother. These events, along with the ordinary case load of civil and criminal cases Counsel deals with, has delayed Counsel’s completion of the Appellant’s Brief. V. Insufficient Time to Complete Brief: Counsel would show that based upon the above and forgoing, that he has had insufficient time within which to complete the Brief. VI. Requested Relief: Counsel requests that the deadline for filing Appellant’s Brief be extended to August 25, 2015. The subject request for extension is not sought for delay, but only that justice may be done. VII. Conference: Counsel would show that he conferred with opposing counsel and this Request is presented as UNOPPOSED. VIII. Word Count Certificate: Counsel certifies that WORD format character count is 434. WHEREFORE, PREMISES CONSIDERED, Counsel requests that this Notice be filed among the papers in this matter. 2 WHEREFORE, PREMISES CONSIDERED, counsel requests that this Motion be granted. Respectfully submitted, Sten M. Digitally signed by Sten M. Langsjoen DN: cn=Sten M. Langsjoen, o, ou, Langsjoen email=sten@langsjoenlaw.com, c=US Date: 2015.08.24 21:43:01 -05'00' _______________________________ STEN M. LANGSJOEN Attorney for Appellant P.O. Box 539 Tyler, Texas 75710 Telephone: (903) 531-0171 Telefax: (903) 531-0187 TBA # 11922800 CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing was delivered by certified mail, return receipt requested, and/or by "fax" transmission and/or by hand-delivery to District Attorney, Cherokee County, Texas, on this 24th day of August, 2015. Sten M. Digitally signed by Sten M. Langsjoen DN: cn=Sten M. Langsjoen, o, ou, Langsjoen email=sten@langsjoenlaw.com, c=US Date: 2015.08.24 21:43:34 -05'00' ____________________________ STEN M. LANGSJOEN 3