Casey Austin Jones v. State

ACCEPTED
06-15-00113-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
11/18/2015 10:55:02 AM
DEBBIE AUTREY
CLERK

NO. 06-15-00113-CR

IN THE COURT OF APPEALS FILED IN
FOR THE SIXTH APPELLATE DISTRICT 6thTEXARKANA,
COURT OF APPEALS
TEXAS
AT TEXARKANA 11/18/2015 10:55:02 AM
DEBBIE AUTREY
Clerk

CASEY AUSTIN JONES

VS.

THE STATE OF TEXAS

APPEALED FROM THE 71ST DISTRICT COURT, HARRISON COUNTY
TRIAL CAUSE NO. 12,0154X

MOTION FOR EXTENSION OF TIME TO FILE
BRIEF FOR CASEY AUSTIN JONES, APPELLANT

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW CASEY AUSTIN JONES, Appellant herein, and

pursuant to Rule 10.5(b), TEX. R. APP. PROC., and pursuant to the extension

policies of this Court, makes this request to extend filing the brief in this

cause and would show as follows:

The Official Court Reporter has filed the Reporter’s record with this

Honorable Court. The undersigned has received copies of that record as well

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as the Clerk’s Record. The deadline for filing Appellant’s Brief is on or before

November 23, 2015.

II.

Appellant requests an additional thirty (30) days in which to complete the

research and writing necessary for submission of the brief.

III.

As reasonable explanation for the need for an extension of time Appellant

would show as follows:

While counsel for Appellant has devoted time to reading the record,

research, and drafting the Brief, the Brief is not yet finished. Moreover, on or about

November 4, 2015, the supplement to the Reporter’s Record was filed, containing

the record of the hearing on the motion for new trial, an essential part of the appeal.

Appellate counsel has also during the past thirty days devoted his time to

other matters in his office, including, but not limited to, the following matters:

Work on Criminal Appeals

Continued correspondence with Appellant in Esaw Lampkin v. State, No.

06-14-00024-CR, now PD-1333-15 in Court of Criminal Appeals.

Work on presenting a motion for new trial on October 28, 2015, in Cause No.

43,014-A, State v. Fred Wright, Jr., an appeal out of Gregg County; this Court’s

number in Cause No. 06-15-00153-CR.

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Probate & Estate Work (All in Gregg County)

Cause No. 2014-0317-P In re Estate of Baker: work on third amended report

of attorney ad litem for unknown heirs

Cause No. 2015-0308-E In re Estate of Williams: work on answer and report

of attorney ad litem for unknown heirs

Cause No. 2015-0297-E In re Estate of Roberts: work on investigating into

heirship and file answer as attorney ad litem for unknown heirs

Child Protective Services Work (All in Gregg County)

CPS conferences, court hearings, correspondence in the following cases:

No. 2007-7811-DR, “Interest of M.W. , J.W., and C. F.”

No. 2015-178-DR, “Interest of X.D.T.”

No. 2015-1671-DR, “Interest of D.V. and E. H.”

No. 2015-1190-CCL2, “Interest of G.O.”

Drafted and filed memorandum of law in following case:

No. 2014-873-DR, “Interest of J. K. V.”

Counsel has also spent several hours in conference during each week of the

past 30-day period with clients who have consulted with counsel on such diverse

areas of law as collections, criminal law, probate, juvenile, and other legal matters.

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With a grant of an additional thirty days Appellate counsel plans to finish writing

the brief and submit it to the Court.

IV.

There has previously been no motion filed for extension of time, or grants of

time extended to Appellant, for the filing of Appellant's brief.

WHEREFORE, PREMISES CONSIDERED, CASEY AUSTIN JONES,

Appellant, respectfully requests that this Honorable Court of Appeals will, upon

reviewing this Motion, grant the extension of time for filing Appellant's brief as

requested herein, and for such other relief to which Appellant may be entitled.

Respectfully submitted,

LAW OFFICES OF LEW DUNN

_/s/ Lew Dunn_
Lew Dunn Attorney at Law
201 E. Methvin, Suite 102
P.O. Box 2226
Longview, Texas 75606
903-757-6711
FAX 903-757-6712
Texas State Bar No. 06244600
ATTORNEY FOR APPELLANT

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing Motion

is being sent by electronic transmission to the office of Hon. Laura Carpenter,

Assistant Criminal District Attorney, Harrison County Courthouse, 200 W.

Houston Street, Suite 206, Marshall, Texas 75670 on this 18th day of November,

2015, email address: laurac@co.harrison.tx.us.

/s/_LewDunn_____________
Lew Dunn
COUNSEL FOR APPELLANT