George Washington Sharper v. State

ACCEPTED 06-15-00114-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 9/15/2015 3:30:16 PM DEBBIE AUTREY CLERK NO. 06-15-00114-CR FILED IN 6th COURT OF APPEALS GEORGE WASHINGTON § IN THE COURTTEXARKANA, TEXAS SHARPER 9/15/2015 3:30:16 PM DEBBIE AUTREY § Clerk VS. § OF APPEALS § §STATE OF TEXAS SIXTH APPELLATE DISTRICT MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes GEORGE WASHINGTON SHARPER, 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 196th Judicial District Court of Hunt County, Texas. 2. The case below was styled State of Texas v. George Washington Sharper, Cause No. 28,240. 3. Appellant was convicted in Cause 28,240 of Capital Murder and was sentenced to life in prison without parole in the Texas Department of Corrections, Institutional Division. 4. Notice of appeal was given on July 16, 2015. 6. The clerk's record in this case was filed on August 14, 2015; the reporter's record in this case was filed on August 14, 2015. 7. The appellate brief in each case is presently due on September 16, 2015. 8. Appellant requests an extension of time of forty-five (45) days from the present date. 9. No extension to file the brief has been received in these causes. 10. Defendant is currently incarcerated. 11. Appellant relies on the following facts as good cause for the requested extension: Appellant’s attorney, Katherine A. Ferguson, has requested the record, but Appellant’s attorney requests additional time to sufficiently analyze the material contained in the lower court proceedings in order to effectively prepare a brief in this case. The reporters’ record from the trial consists of multiple volumes. Appellant’s Counsel was required to substitute for her law partner as attorney ad litem for the child in a bench trial for termination of parental rights on September 15, 2015 in Cause No. 81,317 in the 196th Judicial District Court styled In re: Jax McManus, Minor Child. Appellant’s Counsel further shows that on September 14, 2015, counsel represented her client in a motion to revoke probation proceeding in the 196th Judicial District Court of Hunt County, Texas, in cause No. 26,408 styled The State of Texas v. Geisha Gwen Barnes. Appellant’s Counsel further shows that counsel is working to prepare for a motion to revoke probation hearing on September 16, 2015 in Cause Nos. 29,139 & 29,411 in the 354th Judicial District Court styled The State of Texas v. Corey Colbert. 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, RENSHAW, DAVIS & FERGUSON, LLP By: /s/ Katherine A. Ferguson Katherine A. Ferguson (SBN 06918050) 2900 Lee Street, Suite 102 P.O. Box 21 Greenville, Texas 75403-0021 Tel: (903) 454-6050 Fax: (903) 454-4898 Email: fergusk66@gmail.com CERTIFICATE OF SERVICE This is to certify that on September 15, 2015, a true and correct copy of the above and foregoing document was served on the Hunt County District Attorney's Office, Hunt County Courthouse, 4th Floor, Greenville, Texas by hand delivery. /s/ Katherine A. Ferguson Katherine A. Ferguson