ACCEPTED
06-15-00012-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
8/31/2015 3:03:32 PM
DEBBIE AUTREY
CLERK
No. 06-15-00012-CR, 06-15-00013-CR, 06-15-00014-CR, 06-15-00015-CR, 06-15-00016-CR, 06-15-00017-
CR
In the Court of Appeals for the FILED IN
Sixth District of Texas 6th COURT OF APPEALS
At Texarkana TEXARKANA, TEXAS
8/31/2015 3:03:32 PM
DEBBIE AUTREY
Clerk
GARY MORROW,
Appellant
v.
STATE OF TEXAS,
Appellee
SECOND MOTION FOR EXTENSION OF TIME
TO FILE BRIEF OF APPELLANT GARY MORROW
COMES NOW, Micah Belden, Counsel for Gary Morrow, and moves for a thirty day
extension of time and would show:
The Court Reporter's record was filed on June 29, 2015. Counsel has been unable to file
his Appellant's brief herein by the extended deadline of August 28, 2015, due to the very large
volume of the reporter's record which is in approximately ten volumes and over two thousand
pages. Additionally, the reporter's record will have to be supplemented with the motion for new
trial hearing, as it has one of the key appeal points placed on the record regarding punishment
evidence. Counsel prays that the deadline be extended until September 27, 2015, at which time
Counsel represents that he should be able to file the appellant's brief in all reasonable likelihood.
Counsel has had two jury trial settings in the last five weeks, both of which went to trial although
one pled after voir dire, and is a solo practitioner working diligently on the brief. However, it is
an unusually long record (believed to be the longest this attorney has dealt with in a non-capital
case), and the case involves complex issues including ownership for burglary purposes between
two spouses and whether an expert should have been hired for punishment.
Respectfully submitted,
Is! Micah Belden
Micah Belden
711 N. Travis
Sherman, TX 75090
Telephone: (903) 744-4252
Fax: (903) 893-1734
State Bar No. 24044294
Board Certified in Criminal Law
Texas Board of Legal Specialization
CERTIFICATE OF SERVICE
I do hereby certify that on this August 28, 2015, a true and correct copy of this motion
was forwarded by email to:
Brad Setterberg
Assistant Fannin County District Attorney
101 E. Sam Rayburn, Third Floor
Bonham, TX 75418
VERIFICATION
BEFORE ME, the undersigned authority, on this day personally appeared 1 t 84de"
, who
after being duly sworn stated:
"My name is ,/P 1Af (-PO . I am the petitioner in the above entitled and numbered
7feet
cause. I have read the attached Petition for Occupational Driver's License and hereby
state that said Petition is true and correct to the best of my knp ledge."
SUBSCRIBED AND SWORN TO BEFORE ME on , 2015, to certify which
witness my hand and seal of office.
B JERRY McGOWEN III
NOTARY PUBLIC
STATE OF TEXAS
My Comm. Exp. 02/14/2010 Notary Pub)lic,‘State of Texas