ACCEPTED
01-14-00930-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/8/2015 12:42:45 PM
CHRISTOPHER PRINE
CLERK
Cause No. 01-14-00930-CR
FILED IN
BRIDGET RENAE MILLER, * IN THE COURT 1st
OF COURT OF APPEALS
APPEALS
Appellant * HOUSTON, TEXAS
4/8/2015 12:42:45 PM
*
VS. * FIRST DISTRICT
CHRISTOPHER A. PRINE
Clerk
*
THE STATE OF TEXAS, *
Appellee * HOUSTON, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF
Comes now BRIDGET RENAE MILLER, through her attorney of
record John J. Davis, and files this Motion For An Extension
of Time in which to file Appellant's Brief pursuant to Rules
10.5(b) and 38.6(d) of the Texas Rules of Appellate
Procedure. In support of this Motion, Appellant shows the
Court the following:
I.
TRIAL COURT: 239th District Court of Brazoria County, Texas,
Judge Pat Sebesta, presiding.
CAUSE NUMBER: 74,2 32
STYLE: The State of Texas vs. Bridget Renae Miller
DATE OF JUDGMENT: November 10, 2014
CONVICTION (OFFENSE): Injury to a Child
SENTENCE: Ninety-nine (99) years TDCJ-ID
DEADLINE FOR FILING APPELLANT'S BRIEF: 8 April 2015
LENGTH OF TIME REQUESTED FOR EXTENSION: 18 May 2015
(40 days)
NUMBER OF PREVIOUS EXTENSIONS GRANTED: None
II.
REASONS FOR EXTENSION
Appellant's request for an extension is based upon the
following facts:
On March 17, 2015, Appellant's counsel completed and
submitted a brief to this Court in Docket Number 01-14-00727-
CR styled Alphonso Smith vs. The State of Texas.
The record in the instant case is comprised of sixteen
(16) volumes, 9 of which are reporter's record and seven (7)
of which are exhibts. The trial itself constitutes 1162 pages
excluding exhibits.
In addition to this brief, this attorney is the defense
counsel for the Brazoria County Drug Court which meets every
week and requires additional time for client conferences.
Counsel is also the appointed defense counsel at probation
reviews in the 149th and 239th District Courts as well as the
appointed defense counsel for the jail dockets in County
Court at Law Number 1 of Brazoria County. The length of this
record coupled with the settings and requirements of the drug
court and the review and jail dockets have resulted in
Counsel being unable to finish the brief by the stated
deadline.
WHEREFORE, PREMISES CONSIDERED, Appellant prays the
Court grant this MOTION FOR EXTENSION OF TIME TO FILE
APPELLANT'S BRIEF and extend the time for filing the Brief
until 18 May 2015.
Respectfully submitted,
/s/ John J. Davis
John J. Davis
P.O. Box 787
2 05 N. Chenango
Angleton, Texas 77516-0787
SBN 05515500
Telephone: (979) 849-4362
d.attorne@sbcglobal.net
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the
above MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF
was served to:
Jeri Yenne
Criminal District Attorney
Brazoria County Courthouse
111 East Locust, Suite 408A
Angleton, Texas 77515
ATTENTION: David Bosserman
VIA FACSIMILE (979) 864-1525
on the 8th day of April 2015
/s/ John J. Davi:
John J. Davis
Attorney for Appellant