ACCEPTED
06-15-00117-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
9/15/2015 5:18:00 PM
DEBBIE AUTREY
CLERK
Cause No. Q 6-15-001 17—CR
JOSEPH STREHLIII § IN THE COURT OF APPEALS
§
6TH FILED IN
V. § APPELLATE
6thDISTRICT
COURT OF APPEALS
§ TEXARKANA, TEXAS
STATE OF TEXAS TEXARKANA,9/16/2015
TEXAS 8:13:00 AM
DEBBIE AUTREY
MOTION TO EXTEND TIME TO FILE BRIEF Clerk
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, Appellant, through JEFF SANDERS, Defense Attorney, in the above
styled and numbered cause and files this Motion and in support thereof would show the Court as
follows:
1. The Appellant’s Brief is due on September 21, 2015. Appellant’s attorney needs 30
additional days to file the brief. This is the first request for an extension.
2. During the past 30 days, Counsel has been preparing for a juvenile discretionary
transfer hearing in Cause Number 003-0157-l5, In the Matter of Q.H., in Smith
County, Texas. Additionally, Counsel has been preparing two cases for client
Thomas Overman on the Rusk County trial docket. One is identified as Cause
Number CR14-334-1 (state jail felony theft) and the other is identified as Cause
Number CRl4—268 (non-compliance with sex offender registration requirements).
I’Ve also been working on and investigating an unindicted aggravated assault charge
in Smith County, styled State V. Lee Matthew Harrell.
3. This motion is not made for purposes of delay, but so that justice may be done.
WHEREFORE, PREMISES CONSIDERED, the Appellant requests that this motion for be granted.
State Bar Number 24033153
ELLIS and SANDERS PLLC
120 S. Broadway Suite 112
Tyler,Texas 75702
Phone (903)595-1131 Fax (903)595-5532
CERTIFICATE OF SERVICE
This a true and correct copy of the foregoin Motion was served upon the attorney
is to certify that
for the State on 15th of September, 2015.
VERIFICATION
STATE OF TEXAS §
§ KNOW ALL MEN BY THESE PRESENTS
COUNTY OF SMITH §
“My name is JEFF SANDERS and I am the attorney for the Appellant in this case. I have
knowledge of the facts stated in the foregoing Motion and they are true and correct.”
Signedon .~Ler /5‘ ,2o15.
/}////aw,-
J%1=$%NDERs
SWORN AND
J SUBSCRIBED TO BEFORE ME, the undersigned Notary Public on
Qua
. / , 2015.
in and folghe State of Texas 2 ""5 “um”
My povmmlon Expires
mm: 13. 2017