Dedric Dshawn Jones v. State

ACCEPTED 01-15-00717-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/9/2015 12:00:33 PM CHRISTOPHER PRINE CLERK CAUSE NO. 01-15-00717-CR EXPARTE § IN THE COURT OF APPEALS FILED IN § 1st COURT OF APPEALS § HOUSTON, TEXAS § 12/9/2015 12:00:33 PM DEDRIC DSHAWN JONES § 1ST DISTRICT CHRISTOPHEROF TEXAS A. PRINE Clerk APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF ON BEHALF OF APPEALLANT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Appellant, DEDRIC DSHAWN JONES, by and through the undersigned attorney of record filing this Motion for Extension of Time to File Appellate Brief on Behalf of the Defendant and would show unto the Court the following: 1. Appellant’s brief is currently due on December 14, 2015. 2. On November 30, 2015, Appellant’s attorney, Adam B. Brown was set for trial in the case styled State of Texas v. Jimmy Law; Cause No. 15CR1329; pending in the 405th Judicial District Court of Galveston County, Texas. The Honorable Michelle M. Slaughter presiding. 3. On December 2, 2015, Appellant’s attorney is set for trial in the case styled State of Texas v. Edwin Blanco; Cause No. 1457256; an aggravated sexual assault of a child case pending in the 177th Judicial District Court of Harris County, Texas. The Honorable Ryan Patrick presiding. 4. On December 7, 2015, Appellant’s attorney is set for trial in the case styled State of Texas v. Robert Thomas; Cause No. 15CR0745, pending in the 56th Judicial District Court of Galveston County, Texas. The Honorable Lonnie Cox presiding. 5. On December 15, 2015, Appellant’s attorney is set for a presentence investigation hearing in the case styled State of Texas v. Thomas Graham, a murder case pending in the 10th District Court of Galveston County, Texas. 6. Appellant’s attorney respectfully requests a 30 day extension from date Appellant’s brief is due. 7. This request is in the interest of justice and not merely to seek delay. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Motion be GRANTED. Respectfully submitted, /s/ Adam B. Brown ADAM B. BROWN TBA No. 24003775 300 Main Street, Suite 200 Houston, Texas 77002 Telephone: (713) 223-0051 Facsimile: (713) 228-0034 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Motion was filed electronically with the First Court of Appeals on this the 9th day of December 2015. /s/ Adam B. Brown ADAM B. BROWN