Joseph Tate Bailey v. State

ACCEPTED 01-15-00215-CR FIRST COURT OF APPEALS FILED IN HOUSTON, TEXAS st 1 COURT OF APPEALS 6/15/2015 12:00:00 AM HOUSTON, TX CHRISTOPHER PRINE CLERK June 15, 2015 CHRISTOPHER A. PRINE, NO. 01-15-00215-CR CLERK FILED IN JOSEPH BAILEY 1st OF IN THE 1 ST COURT COURT OF APPEALS APPEALS HOUSTON, TEXAS 6/14/2015 3:04:36 PM VS. CHRISTOPHER A. PRINE Clerk THE STATE OF TEXAS HOUSTON, TEXAS FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE JUDGES OF SAID COURT: COMES NOW LANA GORDON, Appointed counsel for Appellant,JOSEPH BAILEY, who files this Motion and as grounds therefore would show as follows: I. Counsel was appointed to represent Mr. Bailey who was charged with Murder. Upon a plea of not guilty, a jury convicted him of Murder in cause number 1411201 in the 248 th District Court on February 24, 2015. Notice of Appeal was timely given after the jury assessed punishment at 35 years in prison. The brief was due June 12, 2015. Apologizing to this Honorable court for the late filing of this Motion for Extension of Time to File Brief, Counsel requests one sixty day extension. II. Counsel has had various professional and personal matters which made it impossible to have the brief filed on the original due date of June 12, 2015. Counsel also has other appellate cases to address: Ex Parte Taylor, Williams v. State, Ex Parte January, Ex Parte Cain, Siros v. State and Adekeye v. State, including two capital murders, among others. Further, counsel is the primary person caring for an elderly, very ill relative now and there have been various health crises she has addressed for him in the last month, taking much of counsel’s time and energy. II. This case is complex, with complicated legal issues regarding a significant amount of time to organize and present in a brief. III. Counsel requests one 60 day extension, causing the brief to be due August 12, 2015. WHEREFORE, PREMISES CONSIDERED, Counsel prays that this Honorable Court grant this Motion to Extend Time to File Appellant’s Brief and permit her to file it on or before August 12, 2015. Respectfully Submitted, /s/ Lana Gordon Lana Gordon Counsel for Appellant TBN: 08202700 3730 Kirby, Suite 1120 Houston, Texas 77098 TEL: (713) 520-5223 FAX: (713)520-5455 Lanagordonlaw@aol.com CERTIFICATE OF SERVICE On June 14, 2015, this Motion was served upon the State of Texas, Harris County District Attorney’s office by e-service herein. /s/Lana Gordon LANA GORDON