Jonathan Young v. State

ACCEPTED 14-15-00257-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 8/6/2015 3:18:29 PM CHRISTOPHER PRINE NO. 14-15-00257-CR CLERK IN THE COURT OF APPEALS FOR THE FOURTEENTH DISTRICT OF TEXAS FILED IN 14th COURT OF APPEALS AT HOUSTON HOUSTON, TEXAS 8/6/2015 3:18:29 PM CHRISTOPHER A. PRINE Clerk JONATHAN YOUNG, Appellant § § vs. § § THE STATE OF TEXAS, Appellee § MOTION FOR EXTENSION OF TIME TO FILE BRIEF ON APPEAL FROM CAUSE NO. 1421419 IN THE 183rd DISTRICT COURT OF HARRIS COUNTY, TEXAS Thomas J. Lewis State Bar No. 12308540 1601 Washington Ave. Houston, Texas 77007 Phone: (713) 256-6779 Fax: (713) 861-2951 E-Mail: tjlaw2@comcast.net ATTORNEY FOR APPELLANT TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW JONATHAN YOUNG, APPELLANT, and moves the Court to extend the time for filing a brief herein, and in support thereof would show as follows: I. Appellant was convicted of the offense of delivery of a controlled substance in an amount greater than 400 grams and sentenced on March 6, 2015 to a term of 30 years in prison. II. The brief herein is due on August 5, 2015. Appellant’s counsel is a sole practitioner and is currently preparing briefs on three other cases. Appellant’s counsel has just completed a brief in a capital murder case, Tyran Riley v. State, 14- 14-00081-CR, filed on this date. III. Appellant counsel requests an extension of 35 days, making the brief due on September 9, 2015, so the Appellant may receive effective assistance of counsel. WHEREFORE, PREMISES CONSIDERED, Defendant prays this Court to grant this Motion and extend the time for the filing of a brief herein. Respectfully submitted, Thomas J. Lewis State Bar No. 12308540 1602 Washington Ave. Houston, Texas 77007 Phone: (713) 256-6779 Fax: (713) 861-2951 E-Mail: tjlaw2@comcast.net ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE I the undersigned attorney certify that a true copy of the foregoing was served on the District Attorney of Harris County, Texas, by e-mail delivery to Curry_Alan@dao.hctx.net on this the 6th day of August, 2015. ______________ Thomas J. Lewis