Louanne Larson v. State

FILED )H The Court of %pea)s Sixth District ^^rl^JU Sixth District No, 06-15-00178-CR DEC 2 fi 2015 LOUANNE LARSON ^ ?fl m § IN THE COURT OF APPE^S^^ ^^ MDvant__ _ ^ DebraK.^utMy^G^k VS. .-'f'^^r^iP'J^P^lf1 Dsbra Autrey, Clerk " § SIXTH APPELLATE DISTRICT STATE OF TEXAS § TEXARKANA, TEXAS APPELLEE § FIRST MOTION TO EXTEND TIME FOR FILING APPELLANT'S BRIEF TO THE HONORABLE COURT OF APPEALS JUDGES: COMES NOW, Louanne Larson, appellant, pro se, and respectfully moves the Court to extend the time for filing AppellantTs Brief, and, in accordance with T.R.A.P. 73, submits the following: 1. Trial Court Case Number: 10,846 2. Style of Case: State of Texas VS. Louanne Larson 3. Trial Court: 115th District Court of Marion County, Texas 4. Offense: Capital Murder 5. Punishment Assessed: Life confinement in TDCJ to serve 35 calendar years before parole eligibility B. Length of Extension Sought: 14 Days 7. Facts Relied Upon to Reasonably Explain the Need for an Extension: On December 14, 2015 response was received From the Court of Appeals District Clerk stating that the Trial Court 's Reporter's Record Statements of Facts had not been received at yourr Honorable Court. The Motion For Forensic Trace Evidence Search and DNA Testing relies on the statements of facts volumes and page numbers therein to verify and prove the truth and accuracy of the matter, without which, the Court cannot Z?jul^ bfffgf determine the facts. Secondly, I was informed the appellant's brief was due on or before December 09, 2015. I did not receive the letter until December 14, 2015 at the Mountain View Unit Mailroom, 5 days after the due date. I was not aware that an appellant's brief was required, as I relied on Texas Code of Criminal Procedure Article 64 and submitted the Motion and Accompanying Affidavit that contain the volume and page numbers to prove facts, state and federal case laws supporting my argument, exhibits, and documentation supporting the need for the Motion to granted and the trace evidence search and testing done. I did not intentionally or neglectfully fail to file the appellant's brief, I wasn't aware it was required. I beg the Court to grant the extension, or in the alternative, consider the Motion and Affidavit as appellant's brief. I throw myself on the mercy of the Honorable Court. WHEREFORE, PREMISES CONSIDERED, Movant prays that this Court will extend the time within which to File Appellant Ts Brief for 14 days, or whichever time the Court finds reasonable and acceptable. Respectfully submitted, Louanne Larson TDCJ 6649981, Pro se Mountain View Unit 2305 Ransom Road Gatesville, Texas 75528 UNSWORN DECLARATION I, Louanne Larson, TDCJ No. 649981, being presently incarcerated in Texas Department of Criminal Justice, Mountain View Unit, 2305 Ransom Road, Gatesville, Coryell County, Texas, (X^fc-^-*— 6