ACCEPTED
01-15-00330-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
9/16/2015 9:49:32 AM
CHRISTOPHER PRINE
CLERK
No. 01-15-00330-CR
__________________________________________________________________
FILED IN
1st COURT OF APPEALS
IN THE FIRST COURT OF APPEALS, TEXAS HOUSTON, TEXAS
AT HOUSTON 9/16/2015 9:49:32 AM
______________________________________________
CHRISTOPHER A. PRINE
Clerk
JAMES JACKSON,
Defendant-Appellant,
v.
THE STATE OF TEXAS,
Plaintiff-Appellee.
______________________________________________
On Appeal from the 248th Judicial District Court
Trial Court Case No. 1359103
______________________________________________
APPELLANT’S
MOTION FOR EXTENSION
OF TIME TO FILE INITIAL BRIEF
________________________________________________
Robert L. Sirianni, Jr., Esq.
Texas Bar No. 24086378
The Law Firm of Robert L. Sirianni, Jr.
201 N. New York Ave. Suite 200
P.O. Box 2047
Winter Park, Florida 32790
Tele: 407.388.1900
Fax: 407.622.1511
Robert@brownstonelaw.com
Counsel for Defendant-Appellant
__________________________________________________________________
September 16, 2015
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW, DEFENDANT-APPELLANT JAMES JACKSON,
through undersigned counsel in the above-styled cause, and respectfully submits this
Motion for Extension of Time to File Initial Brief, and as grounds would show unto
the Court the following:
1. Defendant-Appellant James Jackson recently retained the firm
Brownstone, P.A. and Robert L. Sirianni, Jr. to represent him on appeal.
2. The Initial Brief was due on August 27, 2015.
3. Undersigned counsel has not yet received the reporter’s and clerk’s
records, therefore, additional time will be necessary for Attorney Sirianni to
review said record, conduct the required research, and prepare the Initial Brief.
4. Accordingly, in the abundance of caution, Defendant-Appellant James
Jackson respectfully requests that this Court grant a 45-day extension of time,
up to and including October 11, 2015, to file the Initial Brief in this cause.
5. This extension of time is not requested for the purpose of delay, but so
that the issues on appeal are presented in the clearest and most effective
manner so that justice may be done in this cause. This is undersigned’s first
request for an extension of time.
WHEREFORE, Premises Considered, Defendant-Appellant respectfully
requests the entry of an order granting a 45-day extension of time, up to and
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including October 11, 2015, to file the Initial Brief and to provide such further and
other relief that the Court may deem just, fair and equitable.
Respectfully Submitted,
/s/ Robert L. Sirianni, Jr.
Robert L. Sirianni, Jr.
Texas Bar No. 24086378
BROWNSTONE, P.A.
201 N. New York Ave. Suite 200
P.O. Box 2047
Winter Park, Florida 32790
Tele: 407.388.1900
Fax: 407.622.1511
Robert@brownstonelaw.com
Counsel for Defendant-Appellant
CERTIFICATE OF SERVICE
Undersigned hereby certifies that on this 16th day of September, 2015, the
foregoing document has been filed electronically which will serve all counsel of
record.
/s/ Robert L. Sirianni, Jr.
Robert L. Sirianni, Jr., Esq.
CERTIFICATE OF COMPLIANCE
Undersigned counsel certifies that the body of this document contains 238
words according to Microsoft Word.
/s/ Robert L. Sirianni, Jr.
Robert L. Sirianni, Jr., Esq.
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