Temika Charnette Owens v. State

ACCEPTED 06-15-00069-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 7/17/2015 3:30:07 PM DEBBIE AUTREY CLERK No. 06-75-00069-e. FILED IN IN The Sixth Court of Appeals 6th COURT OF APPEALS TEXARKANA, TEXAS Texarkana, Texas 7/17/2015 3:30:07 PM DEBBIE AUTREY Clerk TEMTK;A CTIERNETTE Oq|IENS, Appellant, v. THE STATE OF TENAS, Ay>peJ'lee. F'irst Unopposed Motion for Hxtension of Time to FiTe Ag>pellatzt' s Brief TO THE HONORABLE SIXTH COURT OF APPEALS: Pu::suant to TEX. R. APP. P. 10.1 and 38.6(d) , the Appellant, Temika Charnette Owens, files this Unopposed First. Mot.ion t.o Extend Time to File Appellant's Brief . Appel-Lant' s brief is currently due on July 2J , 20L5 . Counsel for Appellant request.s a 3O-day extension of time l-o file its brief, making the brief due on August 26, 2075. This is the fir:;t. request for extension of time to file Appellantn s Brief. Counsel for Appellant rel-ies on the following reasons/ in addition to the routine matters that counsel must attend to in daily practice, to explain the need for the requested extensron: Tt has j ust come to the att.ention of counsel for Appel-l-ant that the Reporter's Record in this cause i s 'i ncomn'i ef e. Counsel todav realized that. t.he noi^f ion of the Record which should contain the reaCing of the verdict by the foreman of the jury is absent. Counsel has at.tempted to contact the r-orrrf UVLM ren1^,rf er- !EI/V!UgI, anr-l was qlIV vvqJ nnl-i llvu!rfue f i ad l-rrz vJ nof SOnneI Of the 4th Di.strict Court of Rusk County that t.he courL ror)nrt-or lv}/vr Lvr i q oynor-f er-l to he awa\/ *"*J f rom her of fice unt-il sometime next week. Counsel for Appellant seeks this extension of time because it is necessary to review the entire record in order f n nrar\.a rc\ vvY vrr ^n^6nl- P.r-i of Annol I =nf l^^t -.i TJCI-LUVC> a 30 day extension should qive the court reporter enough time to supplement the record with that portion which was omitted This request is not sought for delay but so that justice may be done. The undersigned has conferred with opposing counsel, and opposing counsel has indicated that his client does not oppose this motion. Al.L fzrcts recited in this motion are within the personal know'ltvvYv er^lcre of the counsel s'i r^rni ncr f hi s mol_ i on - f herefore no verification is necessary under Rufe of Appellate Procedure r0.2. PRJAYER FOR RELIEF For the reasons set forth above, Appeflant requests t.hat this Corrrf .rrant l_ h'i s tlnonnosed First MOtion to Extend Time to File Apl?ellant's Brief and extend the Deadl-ine for Filing the Appeflant's Brief up to and including August 26, 2075. Appellant requests all other relief to which it may be entitled. Raqnor-f frr I'l rz qrrl-rmi fu ]_uvs/or^l - ckson SBOT No. 24069916 735-A Hwy 259 N. Kilgore, TX 15662 Phone: 903-65 4-3362 Fax: B 17-B 87-4 333 Af f nrrla\/ fnr Ar,r'>a1l.anf 1qL! u / Temika Charnette Owens CERTIFTCATE OF CONF$RENCE Pursuant to Tnx. R. App. P. 10.1 (5) , I certify that the rrnclersi uf fvvl rrYIIvvonecl conferred wif h onnosi nrr r-rrrrnsel vvsrlvvf / who indicated that his client does NOT o'opose this motion. Jeff T. Jackson CERTIFICATE OF SERVICE Pur:suant to Tnx. R. App. P. 9.5, I certify that on December L2, 2014, a copy of this motion was mailed via first cl-ass U.S. mail, postage prepaid, to the following: Micheerl Jimerson: Rus;k County District Attorney SBOT: 00189406 t1:; N. Main St. Herider:son, TX 15652 Jackson