ACCEPTED
12-15-00071-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
9/30/2015 11:49:46 AM
Pam Estes
CAUSE NO. 12-15-00071-CR CLERK
HAROLD BASS, JR. § IN THE
§
VS. § TWELFTH COURT
FILED IN
§ 12th COURT OF APPEALS
THE STATE OF TEXAS § OF APPEALS TYLER, TEXAS
9/30/2015 11:49:46 AM
MOTION TO PAM ESTES
Clerk
EXTEND TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes 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 114TH Judicial District Court of Smith County,
Texas.
2. The case below was styled State of Texas v. Harold Bass, Jr. and numbered
114-1453-14.
3. Appellant was convicted of Aggravated Assault with a Deadly Weapon.
Appellant was assessed a sentence of twenty-five (25) years confinement in
TDCJ-ID.
5. Notice of Appeal was given on March 11, 2015.
6. The Clerk's Record was filed on May 21, 2015; the Reporter's Record was filed
on June 30, 2015.
7. The Appellant’s Brief is due on September 30, 2015. Counsel requests the Court
an extension of thirty (30) days due to the number of briefs with deadlines.
8. Appellant requests an extension of time due to the following facts and
circumstances.
Since the Reporter’s Record in this case was completed, Counsel has filed:
A. Appellant’s Brief in Donald Powell v. State of Texas, cause number 12-
14-00355-CR filed on July 6, 2015;
B. Appellant’s Petition for Discretionary Review in Fatima Rahman v. State
of Texas, cause number PD-0724-15 filed on July 13, 2015;
C. A subsequent writ of habeas corpus in Ex parte Clifton Williams, cause
number WR-71,296-02 with the Court of Criminal Appeals filed on July
15, 2015;
D. Appellant’s Brief in Ricky Harris v. State of Texas, cause number 12-15-
00104-CR filed on July 20, 2015;
E. Appellant’s Brief in Oscar Perkins v. State of Texas, cause number 12-
15-00001-CR filed on July 22, 2015;
F. Appellant’s Brief in Charlie Motes v. State of Texas, cause number 12-
15-00111-CR filed on August 24, 2015;
G. A Petition Seeking Discretionary Review in PD-1014-15, Steven Michael
Goode v. State, filed on August 31, 2015;
H. Appellant’s Brief in Christopher McLemore v. State of Texas, cause
number 12-15-00091-CR filed on September 4, 2015;
I. Appellant’s Brief in Joe Lynn Pittman v. State of Texas, cause number
12-15-00009-CR filed on September 11, 2015;
J. Appellant’s Brief in Hubert Benjamin v. State of Texas, cause number
12-15-00172-CR filed on September 21, 2015;
K. Appellant’s Briefs in Brittany Michelle Barrett v. State of Texas, cause
numbers 12-15-00145-CR, 12-15-00146-CR, and 12-15-00147-CR on filed
on September 22, 2015;
L. Appellant’s Brief in John Congleton v. State of Texas, cause number 12-
15-00124-CR filed on September 23, 2015; and
M. Petitioner’s Proposed Findings of Fact and Conclusions of Law in 114-
1289-13-A on September 30, 2015, an 11.07 writ of habeas corpous.
9. Counsel has appeared in numerous hearings in state and federal court over the
last thirty days, including hearings in the Eastern District of Texas - Tyler
Division, and hearings in Smith and Van Zandt Counties.
10. Lastly, Appellant’s Counsel has the following briefs pending:
A. Appellant’s Brief in Gaylord Stevens v. State of Texas, cause numbers
12-15-00162-CR, 12-15-00163-CR and 12-15-00164-CR upon the
completion of the Reporter’s Record;
B. Appellant’s Brief in Sidney Lynch v. State of Texas, cause number 12-15-
00167-15 upon the completion of the Reporter’s Record;
C. Appellant’s Brief in Steven Lamon Moore v. State of Texas, cause
number 12-15-00195-CR upon completion of the Reporter’s Record;
D. Appellant’s Brief in Cedric Humble, Jr. v. State of Texas, cause number
12-15-00239-CR upon completion of the Clerk’s Record and Reporter’s
Record; and
E. Appellant’s Brief in Shai’Keston Mackey v. State of Texas, cause number
12-15-00243-CR upon completion of the Clerk’s Record and Reporter’s
Record.
Attorney for the Appellant will be traveling to and preparing in Austin, Texas
for a webcast entitled “Recognizing Mental Health Issues in Your Client”
produced by the State Bar of Texas on Tuesday, October 6, 2015.
11. Appellant requests an extension of time due to the above referenced facts and
circumstances.
12. Appellant prays that this Court grant this Motion to Extend Time to File
Appellant’s Brief for a period of thirty (30) days, and for such other and further
relief as the Court may deem appropriate.
Respectfully submitted,
Law Office of James W. Huggler, Jr.
100 E. Ferguson, Suite 805
Tyler, Texas 75702
Tel: (903) 593-2400
Fax: (903) 593-3830
Jhugglerlaw@sbcglobal.net
By: /S/ James W. Huggler, Jr.
James W. Huggler, Jr.
State Bar No. 00795437
Attorney for APPELLANT
CERTIFICATE OF SERVICE
This is to certify that on September 30, 2015, a true and correct copy of the
above and foregoing document was served on Mike West, Smith County District
Attorney’s Office, 100 North Broadway Ave., 4th Floor, Smith County Courthouse,
Tyler, Texas 75702, by regular mail, fax, hand delivery, or electronic filing.
/S/ James W. Huggler, Jr.
James W. Huggler, Jr.