Jonathan Ray Shepherd v. State

ACCEPTED 06-15-00064-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 10/19/2015 9:37:55 PM DEBBIE AUTREY CLERK 06-15-00064-CR FILED IN JONATHAN RAY SHEPHERD § IN THE SIXTH COURT OF OF APPEALS 6th COURT § TEXARKANA, TEXAS vs. § APPEALS 10/20/2015 9:54:00 AM § DEBBIE AUTREY STATE OF TEXAS § TEXAS Clerk FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE JUDGE OF SAID COURT: Now Comes , JONATHAN RAY SHEPHERD Appellant in the above styled matter, and brings this his First Unopposed Motion for Extension of Time to File Brief pursuant to Tex. R. App. 10(b) and would show the Court as follows: (A) the deadline for filing the item in question; The current deadline for appellant to file his brief is October 16, 2015 (B) the length of the extension sought; The appellant request that Court extend the deadline to file the appellant’s brief until December 1, 2015. (C) the facts relied on to reasonably explain the need for an extension; and The record on this appeal is substantial. The reporter record is twenty volumes and fills an entire banker’s box. This case involves a capital murder conviction wherein the defendant received an automatic life sentence. Counsel has been on the appellate case for approximately 45 days and has begun an exhaustive review of the record. Although, counsel has diligently sought to complete the review and drafting of the appellate brief counsel was not able to complete the drafting of the brief by the October 16, 2015 deadline. (D) the number of previous extensions granted regarding the item in question Counsel has not previously been granted an extension. The Court did extend the deadline for the appellant to file the brief upon counsel’s substitution into this case. FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF Page 1 of 2 WHEREFORE, PREMISES CONSIDERED, JONATHAN RAY SHEPHERD prays that the Court enter an order granting an extension until December 1, 2015 for the appellant to file his brief. Respectfully submitted, The Law Office of Russell Wilson II 1910 Pacific Ave Dallas, TX 75201 Tel: 4695730211 Fax: 972-704-2907 By:/S/ Russell Wilson II____________ Russell Wilson II State Bar No. 00794870 Attorney for JONATHAN RAY SHEPHERD CERTIFICATE OF SERVICE This is to certify that on October 19, 2015, a true and correct copy of the above and foregoing document was served on the Upshur County District Attorney's Office, by email. S/ Russell Wilson II____________ Russell Wilson II CERTIFICATE OF CONFERENCE I conferred with opposing counsel regarding an extension of time in this case was notified that counsel did not oppose this an extension of time S/ Russell Wilson II____________ Russell Wilson II FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF Page 2 of 2