Vincent Alonzo Corson v. State

ACCEPTED 03-15-00057-CR 4536626 THIRD COURT OF APPEALS AUSTIN, TEXAS 3/17/2015 4:44:35 PM JEFFREY D. KYLE CLERK IN THE THIRD COURT OF APPEALS AUSTIN, TEXAS FILED IN 3rd COURT OF APPEALS VINCENT ALONZO CORSON, § AUSTIN, TEXAS Appellant § 3/17/2015 4:44:35 PM JEFFREY D. KYLE § Clerk V. § § CAUSE NO. 03-15-00057-CR § TRIAL COURT NO. 72,780 THE STATE OF TEXAS, § Appellee § MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: NOW COMES VINCENT ALONZO CORSON, Appellant in the above styled and numbered cause, by and through Counsel, and moves this Court to grant an extension of time to file appellant’s brief, pursuant to Rule 38.6(d) of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the 426 th District Court in Bell County, Texas. 2. The case below is styled The State of Texas v. Vincent Alonzo Corson, and numbered 72,780 3. Appellant was convicted of burglary of aggravated kidnapping. 1 4. Appellant was assessed a sentence of forty years in the Institutional Division-Texas Department of Criminal Justice on December 17, 2014. 5. Notice of appeal was given on December 30, 2014. 6. The Clerk’s and Reporter’s records were filed on February 13, 2015 and January 27, 2015, respectively. 7. The Appellant’s brief was due on March 16, 2015. 8. Appellant requests an extension of time to file Appellant’s brief of thirty (30) days or until April 15, 2015. 9. No previous requests for extension to file the brief have been filed in this cause. 10. Defendant is currently incarcerated. Appellant relies on the following facts as good cause for the requested extension: The undersigned has had numerous appellate deadlines in the Courts of Appeal for the Eleventh and Third Districts and the Court of Criminal Appeals in the past forty five days, all of which preceded the filing deadline herein including: filing an Appellant’s Petition for Discretionary Review in State v. Thornburgh, No. 11-12-00328-CR filed March 2, 2015; and filing appellant’s briefs in State v. George, No. 03-14-00673-CR filed 2 March 11, 2015; and State v. Vidaurri, No. 11-14-00291-CR filed January 20, 1015. The undersigned, therefore, would request an additional thirty (30) days to review the record and to perform the necessary legal research for preparation of the brief herein. WHEREFORE, Appellant prays that this Court grant this Motion to Extend Time to File Appellant’s Brief, and for such other and further relief as the Court may deem appropriate. Respectfully submitted, COPELAND LAW FIRM P.O. Box 399 Cedar Park, TX 78613 Tel: 512-897-8126 Fax: 512-215-8114 Email: ecopeland63@yahoo.com By: /s/ Erika Copeland Erika Copeland State Bar No. 16075250 Attorney for Appellant CERTIFICATE OF SERVICE, of COMPLIANCE WITH RULE 9 and of CONFERENCE This is to certify that on March 17, 2015, a true and correct copy of the above and foregoing document was served on Henry L. Garza, District Attorney, Attn: Bob Odom—Appellate Section, P.O. Box 540, Belton, Texas 76513-0909, that the Motion to Extend Time to File Appellant’s Brief is in compliance with Rule 9 of the Texas Rules of Appellate Procedure and that portion which must be included under Rule 9.4(i)(1) contains 525 3 words, and that Movant has conferenced with all interested parties this date concerning the motion and none oppose the motion. /s/ Erika Copeland Erika Copeland 4