ACCEPTED
01-15-00027-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/2/2015 4:02:33 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00027-CR
FILED IN
1st COURT OF APPEALS
EARL WILMORE § IN THE COURT OF APPEALS
HOUSTON, TEXAS
§ 3/2/2015 4:02:33 PM
§ CHRISTOPHER A. PRINE
Clerk
VS. § FIRST DISTRICT
§
§
THE STATE OF TEXAS § HOUSTON, TEXAS
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes EARL WILMORE, 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 Criminal District Court of Jefferson
County, Texas.
2. The case below was styled THE STATE OF TEXAS vs. EARL
WILMORE, and numbered 13-17241.
3. Appellant was convicted of FORGERY.
4. Appellant was assessed a sentence of two (2) years confinement in State
Jail on November 21, 2014.
5. Notice of appeal was given on December 2nd, 2014.
6. The electronic clerk's record was filed on January 2nd, 2015; electronic
reporter's record was filed on January 30, 2015.
7. The appellate brief was due on March 2nd, 2015.
8. Appellant requests an extension of time of 30 days from the present
date, ie. April 1st, 2015.
9. Defendant is currently incarcerated.
10. No extension to file appellant’s brief has been received in this cause.
11. Appellant relies on the following facts as good cause for the requested
extension:
I am a solo practitioner. I have been preparing several cases for trial. It
appears that this case is a complex case and requires adequate time to review this case
to prepare the brief.
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,
Terrence Leon Holmes
Attorney At Law
455 Milam Street
Beaumont, Texas 77701
Tel: (409) 832-6041
Fax: (409) 832-6078
By: /s/ Terrence Leon Holmes
TERRENCE LEON HOLMES
ATTORNEY AT LAW
State Bar No. 09908486
Attorney for APPELLANT
CERTIFICATE OF SERVICE
This is to certify that on March 2nd, 2015, a true and correct copy of the
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF was served on
Mr. Waylyn G. Thompson, District Attorney's Office, 1001 Pearl Street – 3rd Floor,
Beaumont, Jefferson County, Texas, by telecopy (409) 835-8573 via efile.
/s/ Terrence Leon Holmes
TERRENCE LEON HOLMES
ATTORNEY AT LAW