Ronny Lee Williams v. State

ACCEPTED 12-15-00140-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 10/15/2015 4:29:11 PM Pam Estes CLERK NOS. 12-15-00139-CR and 12-15-00140-CR FILED IN STATE OF TEXAS § IN THE 12th COURT OF APPEALS TYLER, TEXAS § 10/15/2015 4:29:11 PM VS. § TWELFTH COURTPAM ESTES § Clerk RONNY LEE WILLIAMS § OF APPEALS MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Ronny Lee Williams, 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. These cases are on appeal from the 145TH Judicial District Court of Nacogdoches County, Texas. 2. The cases below were styled the State of Texas vs. Ronny Lee Williams, and numbered F1320424 and F1521685. 3. Appellant was convicted of Aggravated Robbery, Assault on a Public Servant, and Possession of a Controlled Substance. 4. Appellant was assessed a sentence of seventy-five (75) years, ten (10) years, and twenty (20) years in prison, respectively, on May 19, 2015. 5. Notice of appeal was given on May 20, 2015. 6. The clerk’s record was filed on September 16, 2015, and a supplemental clerk’s record was filed on September 19, 2015; the reporter’s record was filed on August 7, 2015. 7. The appellate brief is presently due on October 16, 2015. 8. Appellant requests an extension of time of one month from the date that the Appellant’s Brief is currently due until November 16, 2015. -1- 9. No previous extensions to file Appellant’s brief have been requested. 10. Appellant is currently incarcerated. 11. Appellant relies on the following facts as good cause for the requested extension: In addition to his usual heavy schedule of criminal announcements and client meetings, over the last two and one-half weeks, Counsel for Appellant had a long, contested temporary hearing out-of-town after an improper post- answer default on a client, two contested bench trials for which to prepare last week, and civil discovery due this week. Counsel for Appellant has not had adequate time to properly research and brief the issues. 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, LAW OFFICES OF NOEL D. COOPER 117 North Street, Suite 2 Nacogdoches, Texas 75961 Telephone: (936) 564-9000 Telecopier: (936) 715-6022 By:/s/Noel D. Cooper Noel D. Cooper State Bar No. 00796397 Attorney for Ronny Lee Williams -2- CERTIFICATE OF SERVICE This is to certify that on October 15, 2015, a true and correct copy of the above and foregoing document was served on Nicole LoStracco, Nacogdoches County District Attorney, 101 West Main Street, Nacogdoches, Texas, via electronic service. /s/Noel D. Cooper Noel D. Cooper CERTIFICATE OF COMPLIANCE Pursuant to TEX. R. APP. P. 9.4(i)(3), I certify that this document is computer generated and contains 334 words based on a computer word count. /s/Noel D. Cooper Noel D. Cooper -3-