ACCEPTED
12-15-00003-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
8/24/2015 2:08:32 PM
CATHY LUSK
CLERK
____________________________________________________________
12-15-00003-CR FILED IN
12th COURT OF APPEALS
_____________________________________________________________
TYLER, TEXAS
8/24/2015 2:08:32 PM
IN THE COURT OF APPEALS CATHY S. LUSK
FOR THE TWELFTH APPELLATE DISTRICT Clerk
TYLER, TEXAS
_____________________________________________________________
DEQUISHA JACKSON
v.
THE STATE OF TEXAS
_____________________________________________________________
APPEAL FROM THE 159TH JUDICIAL DISTRICT COURT
OF ANGELINA COUNTY, TEXAS
BRIEF OF APPELLANT
DEQUISHA JACKSON
_____________________________________________________________
Respectfully, Submitted:
/S/ John D. Reeves
JOHN D. REEVES
Attorney at Law
1007 Grant Ave
Lufkin, Texas 75901
Phone: (936) 632-1609
Fax: (936) 632-1640
SBOT # 16723000
Email: tessabellus@yahoo.com
ATTORNEY FOR APPELLANT
IDENTITY OF PARTIES AND COUNSEL
Parties:
Appellant in Trial Court:
Dequisha Jackson # 01972267
Christina Melton Crain Unit
1401 State School Road;
Gatesville, TX 76599-
Trial and Appellate Counsel:
Appellant:
John D. Reeves Trial Jerry Whiteker John H. Tatum II
Attorney at Law Attorney at Law Tatum Law Office
1007 Grant Ave. P.O. Box 1443 P.O. Box 582
Lufkin, Texas 75901 Lufkin, Texas 75902 Lufkin,Texas 75902
Phone: (936) 632-1609 Phone: 936/634-8568 Ph: 936-639-4480
Fax: (936) 632-1640 SBOT: 21361500 SBOT: 00789674
SBOT # 16723000
Appellee:
Katrina Carswell Trial Katrina Carswell
Angelina County Dist. Atty Angelina County Dist. Atty
P.O. Box 908 P.O. Box 908
Lufkin, Texas 75901 Lufkin, Texas 75901
Phone: 936-632-5090 Phone: 936/ 632-5090
SBOT# 10482700 SBOT# 104822700
TO THE HONORABLE FIRST COURT OF APPEALS:
Pursuant to Tex. R. App. P.10.1 and 38.6 (d), the Appellant, Dequisha
Jackson, of Angelina County, files this his Motion to Extend Time to File
Appellant’s Brief.
Dequisha Jackson’s brief is currently due on August 21, 2015. Counsel for
Dequisha Jackson request a 3 day extension of time to file its brief, to make the
brief due on August 24, 2015. This is the third request for extension of time to file
Appellant’s Brief.
Counsel for Dequisha Jackson relies on the following reasons, to explain the
need for the requested extension.
Counsel has contracted strep throat and has been physically limited in his
ability to work. Further, In addition to preparing this brief, counsel was also
preparing for jury trial this date and needed the weekend to properly proof and edit
the brief.
All facts recited in this motion are within the personal knowledge of the
counsel signing this motion,
PRAYER FOR RELIEF
For the reasons set forth above, Appellant requests that this Court grant this
Unopposed Motion for Leave to File Late Brief and extend the deadline for filing
the Appellant’s Brief up to and including August 24, 2015. Appellant requests all
other relief to which he may be entitled.
/s/John D. Reeves
John D. Reeves
Attorney at Law
1007 Grant Street
Lufkin, Texas 75901
Phone (936) 632-1609 Fax (936) 632-1640
SBOT # 16723000
ATTORNEY FOR APPELLANT
CERTIFICATE OF CONFERENCE
Pursuant to Tex. R. App. 10.1 (5), certify that the undersigned conferred
with opposing counsel who indicated that she does not oppose this motion.
/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 For Leave to File Late Brief on this 24th day of August, 2015 forwarded to
April Ayers-Perez, Assistant District Attorney of Angelina County,
aperez@angelinecounty.net, by e-filing.
__________________________
John D. Reeves
Attorney for Appellant,
Dequisha Jackson