ACCEPTED
03-15-00369-CR
7657475
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/3/2015 12:15:48 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00369-CR
FILED IN
IN THE COURT OF APPEALS 3rd COURT OF APPEALS
AUSTIN, TEXAS
FOR THE THIRD DISTRICT OF TEXAS
11/3/2015 12:15:48 PM
AUSTIN, TEXAS
JEFFREY D. KYLE
Clerk
DACIOUS PARKER
Appellant
V.
THE STATE OF TEXAS,
Appellee
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE
BRIEF
Appeal from the District Court of Travis County, Texas
167th Judicial District
Criminal Action No. D-1-DC-12-600094
Honorable P. David Wahlberg, Judge Presiding
RICHARD D. REED
Lead Counsel for Appellant
316 W. 12th Street
Suite 313
Austin, Texas 78701-1820
Telephone No. 512-322-9443
Email: rick.reed@maverickcounsel.com
State Bar No. 16686100
NO. 03-15-00369-CR
IN THE COURT OF APPEALS
FOR THE THIRD DISTRICT OF TEXAS
AUSTIN, TEXAS
DACIOUS PARKER
Appellant
V.
THE STATE OF TEXAS,
Appellee
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE
BRIEF
TO THE HONORABLE COURT OF APPEALS:
NOW COMES Appellant Dacious Parker, by and through his attorney of
record, Richard D. Reed, and, pursuant to the provisions of Rule 10.5(b), Texas Rules
of Appellate Procedure, respectfully moves the Court to extend the time to file
Appellant’s brief. In support of such motion, Appellant would show unto the Court
as follows:
I.
The deadline for filing Appellant’s brief is November 6, 2015.
II.
Appellant is seeking an extension of thirty-one days.
III.
Appellant needs an extension of time to file Appellant’s brief because
Appellant’s counsel has had to spend most of his time during the past thirty days
attending to other criminal cases to which he has been judicially appointed or
assigned. As a result, Appellant’s counsel has not had sufficient time to review the
record, complete the necessary legal research, and prepare Appellant’s brief.
IV.
No previous extension to file Appellant’s brief has been sought or granted.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays
that the Court grant this motion and extend the time for filing Appellant’s brief to
December 7, 2015.
Respectfully submitted,
______________________________
RICHARD D. REED
Lead Counsel for Appellant
316 W. 12th Street
Suite 313
Austin, Texas 78701-1820
Telephone No. 512-322-9443
Email: rick.reed@maverickcounsel.com
State Bar No. 16686100
Appellant’s First Motion for Extension of Time to File Brief
Page 2 of 3
CERTIFICATE OF SERVICE
I hereby certify that on this, the third, day of November, A.D. 2015, I
personally served a copy of the above-and-foregoing Appellant’s First Motion for
Extension of Time to File Brief upon Rosemary Lehmberg, District Attorney of
Travis County, Texas, whose address is 509 West 11th Street, Suite 1.100, Austin,
Texas 78701-2103, by electronically delivering a copy of the said petition to the
following email address: rosemary.lehmberg@traviscountytx.gov.
I further hereby certify that on this, the third, day of November, A.D. 2015, I
personally served a copy of the above-and-foregoing Appellant’s First Motion for
Extension of Time to File Brief upon Aurora Salina Perez, Assistant District
Attorney of Travis County, Texas, whose address is 509 West 11th Street, Suite 1.100,
Austin, Texas 78701-2103, by electronically delivering a copy of the said petition to
the following email address: aurora.perez@traviscountytx.gov.
I further hereby certify that on this, the third, day of November, A.D. 2015, I
personally served a copy of the above-and-foregoing Appellant’s First Motion for
Extension of Time to File Brief upon Michael Scott Taliaferro, Assistant District
Attorney of Travis County, Texas, whose address is 509 West 11th Street, Suite 1.100,
Austin, Texas 78701-2103, by electronically delivering a copy of the said petition to
the following email addresses: scott.taliaferro@traviscountytx.gov and
appellatetcda@traviscountytx.gov.
I further hereby certify that on this, the third, day of November, A.D. 2015, I
personally served a copy of the above-and-foregoing Appellant’s First Motion for
Extension of Time to File Brief upon Lisa C. McMinn, State Prosecuting Attorney,
whose address is 209 West 14th Street, Austin, Texas 78701-1614, by electronically
delivering a copy of the said petition to the following email address:
lisa.mcminn@spa.texas.gov.
______________________________
Richard D. Reed
Appellant’s First Motion for Extension of Time to File Brief
Page 3 of 3