Geraline Gregory Lincoln v. State

ACCEPTED 14-14-00957-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 3/25/2015 3:12:56 PM CHRISTOPHER PRINE CLERK NO. 14-14-00957-CR NO. 14-14-00959-CR ________________________________________ FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS In the 3/25/2015 3:12:56 PM Court of Appeals CHRISTOPHER A. PRINE For the Clerk Fourteenth District of Texas At Houston ________________________________________ No. 1424405 No. 1424406 In the 337th District Court of Harris County, Texas ________________________________________ GERALINE GREGORY LINCOLN, Appellant v. THE STATE OF TEXAS, Appellee MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE COURT OF APPEALS OF TEXAS: COMES NOW GERALINE GREGORY LINCOLN, the Appellant in the above styled and numbered cause, and pursuant to Rules 10.5(b) and 38.6(d) of the Texas Rules of Appellate Procedure, respectfully moves this Honorable Court to extend the time to file the Appellant’s brief, and in support thereof would show the Court as follows: 1 I. Undersigned counsel was retained on February 5, 2015. II. The deadline for filing the Appellant’s Brief in this case is April 1, 2015. III. The Appellant requests a 30-day extension for filing his Brief. IV. No other extensions have been requested. V. The following facts are relied upon to show good cause for the requested extension: a. This case involves a motion to suppress hearing. b. The appellant was sentenced to eight years in prison. c. The exhibits have not been filed with this Honorable Court and undersigned counsel has not yet viewed them. They are crucial to the appeal and the court reporter is working to supplement the record. d. The Appellant’s motion is not for purposes of delay, but so justice may be done by affording effective assistance of counsel. 2 WHEREFORE PREMISES CONSIDERED, the Appellant respectfully requests that this Honorable Court grant an extension of time until May 1, 2015 in which to file the Appellant’s brief in this case. Respectfully submitted, _/s/ Megan E. Smith MEGAN E. SMITH State Bar No. 24076196 917 Franklin, Suite 310 Houston, Texas 77002 (713) 899-5438 (713) 527-2749 (fax) megan@megansmithlaw.com CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Appellant’s Motion for Extension of Time to File Appellant’s Brief was electronically delivered to Mr. Alan Curry, Appellate Division Chief, Harris County District Attorney’s Office, on this 25th day of March 2015. __/s/ Megan E. Smith____ MEGAN E. SMITH 3