ACCEPTED
06-15-00050-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
8/13/2015 4:17:02 PM
DEBBIE AUTREY
CLERK
NO. 06-15-00050-CR
STATE OF TEXAS § FILED IN
IN THE COURT OF APPEALS
6th COURT OF APPEALS
§ TEXARKANA, TEXAS
vs. § SIXTH APPELLATE DISTRICT
8/13/2015 4:17:02 PM
§
DEBBIE AUTREY
BRAD ALLEN DUNN § HARRISON COUNTY, TEXAS
Clerk
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Brad Allen Dunn, 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 71st Judicial District Court of Harrison County,
Texas.
2. The case below was styled the State of Texas vs. Brad Allen Dunn, and numbered
14-0029X.
3. Appellant was convicted of murder.
4. Appellant was assessed a sentence of ninety-nine (99) years on March 5, 2015.
5. Notice of appeal was given on March 6, 2015 .
6. The clerk's record was filed on July 15, 2015; the reporter's record was filed on
July 8, 2015 .
7. The appellate brief is presently due on August 14, 2015.
8. Appellant requests an extension of time of 60 days from the present date, i.e.
August 13, 2015.
9. No extension to file the brief has been received in this cause.
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10. Defendant is currently incarcerated.
11 . Appellant relies on the following facts as good cause for the requested extension:
Undersigned counsel for Appellant is a sole practitioner actively working in Harrison,
Panola and Shelby Counties. Undersigned counsel almost exclusively handles court-appointed
criminal cases, family law cases, and CPS cases. As those types of cases require attendance in
Court on almost a daily basis, undersigned counsel has had an insufficient amount of time within
which to conduct research, prepare the statement of fact and complete the brief within the stated
time frame. Undersigned counsel would further show he has not had a secretary or paralegal to
help in the day to day activities of his practice, which has further impeded his ability to timely
file this brief.
WHEREFORE, PREMISES CONSIDERED, 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,
CRAIG A FLETCHER
Attorney at Law
110 S. Bolivar, Suite 210
Marshall, Texas 75670
Tel: (903) 503-7676
Fax: (903) 503-7680
By: _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Craig A. Fletcher
State Bar No. 00792506
craig@craigfletcherlaw.com
Attorney for Brad Allen Dunn
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CERTIFICATE OF SERVICE
This is to certify that on August 13, 2015, a true and correct copy of the above and
foregoing document was served on the District Attorney's Office, Harrison County, Harrison
County Courthouse, by email.
Craig A. Fletcher
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