ACCEPTED
06-15-00119-cr
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
12/14/2015 12:20:45 PM
DEBBIE AUTREY
CLERK
NO. 06-15-00119-CR
IN THE
FILED IN
6th COURT OF APPEALS
SIXTH COURT OF APPEALS TEXARKANA, TEXAS
12/14/2015 12:20:45 PM
OF TEXAS
DEBBIE AUTREY
TEXARKANA, TEXAS Clerk
Carlton Daniel Jones,
APPELLANT
THE STATE OF TEXAS,
APPELLEE
On appeal from the 196'" Judicial District Court
Of Hunt County, Texas
Trial Court Cause No. 30,042
APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF
CARLTON DANIEL JONES IN THK COURT OF APPEALS
6TH SUPREME JUDICIAL DISTRICT
STATE OF TEXAS TEXARKANA, TEXAS
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
NO%' COMES CARLTON DANIEL JONES, the Appellant in the above styled and
numbered cause, and would respectfully request an extension of time for filing the Appellee's
brief in said case pursuant to Rule 10.5 and Rule 38 of the Texas Rules of Appellate Procedure,
and would respectfully show the following:
Appellee's brief is due to be filed on or before the 14th day of December 2015,
Appellee respectfully requests this Honorable Court to grant an extension of time to file
the Appellant's Brief for additional thirty (30) days time from this date to complete and file his
Opening, or until the 14'" day of January 2016. In connection therewith, Appellant would show
the following facts relied upon in good faith to show good cause to the Honorable Court of
Appeals regarding this motion for extension of time:
Counsel for Appellant became aware of the record in this case and has made diligent
efforts to review the record and prepare a thorough Opening Brief. Appellant anticipates that
one of the issues for review will concern the sufficiency of the evidence. The record includes
exhibits containing recordings taken from the Hunt County jail and the review of these
conversations has required some effort to obtain recorded copies of the DVD exhibits that are
audible. Appellant has now completed a review of the record and expects to complete the
Opening Brief within a few days of the original due date. Counsel for Appellee does not oppose
this Motion.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests and prays
that the Honorable Court of Appeals grant an extension of thirty (30) days or until January14,
2015 in which the Appellant may complete and file his brief,
Respectfully submitted,
Peter I. Morgan
Counsel For Appellant
State Bar No 14451700
P.O. Box 984
Greenville, Texas 75403
pmorgan@lawyermorgan. corn
(903) 217-3671
(903) 642-0057 (fax)
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing instrument was
forwarded to all parties by hand delivery or regular mail.
Peter I, Morgan
VERIFICATION
STATE OF TEXAS
COUNTY OF HUNT
BEFORE ME, the undersigned Notary Public, on this day personally appeared
PETER I. MORGAN, who being by me duly sworn on his oath deposed and said that he is
duly qualified and authorized in all respects to make this affidavit; that he has read the
above and foregoing Motion for Extension of Time for Filing Brief; and that every
statement contained in the Motion is within 's nowledge and true and correct.
eter I. Morgan
SUBSCRIBED AND SWORN TO BEFORE ME on the day of December
2015, to certify which witness my hand and official seal.
+,w.".'c'~, REBECCA BLEVlNS Notary Public, State of Texas
'p~ Notary Public, State of Texas
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