Vernon Cooks, Jr. v. State

ACCEPTED 06-17-00118-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/4/2017 9:03 PM DEBBIE AUTREY CLERK NO. 06-17-00118-CR FILED IN 6th COURT OF APPEALS STATE OF TEXAS § IN THE TEXARKANA, TEXAS § 12/4/2017 9:03:25 PM VS. § 6th COURT DEBBIE AUTREY § Clerk VERNON COOKS, JR. § OF APPEALS, § TEXARKANA MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF, 2nd TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Vernon Cooks, Jr., Appellant in the above styled and numbered cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the 196th Judicial District, Hunt County, Texas. 2. The case below was styled the STATE OF TEXAS vs. Vernon Cooks, Jr., and numbered 28,190. 3. Appellant was convicted of “Stalking”. 4. Appellant was assessed a sentence of 910 Days – June 7, 2017. 5. Notice of appeal was given on June 9, 2017, a Motion for New Trial was filed on June 23, 2017. 6. The clerk's record was filed on November 3, 2017; the reporter's record was filed on July 31, 2017. 7. The appellate brief is presently due on December 4, 2017. 8. Appellant requests an extension of time of 30 days from the present date. 9. One extension to file the brief has been received in this cause. 10. Defendant is currently free on bond. 11. Appellant relies on the following facts as good cause for the requested extension: Counsel is was set to begin a Jury trial Jesus Soto, Plaintiff vs. Jose Mejia Cause No. CV42301; in the District Court, Hopkins County, Texas on November 20, 2017, but was just nonsuited not long before hand. Counsel was then on vacation from November 21, 2017 through November 26, 2017. Counsel is also appointed in Cumpian, II v. State of Texas Cause No: 06-17- 00062-CR with a Brief due December 11, 2017 Counsel is also appointed in Ham v. State of Texas Cause No: 06-17-00145- CR With a brief due December 18, 2017 Counsel is also appointed in Gonzales v. State of Texas Cause No: 06-17- 000146-CR, with a brief due December 13, 2017. Counsel is also appointed in Sands v. State of Texas Cause No: 06-17-000100- CR with a brief due December 29, 2017 WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this Motion To Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate. Respectfully submitted, JASON A DUFF 2615 Lee St. P.O. Box 11 GREENVILLE, TX 75069 Tel: 903.455.1991 Fax: 903.455.1417 Jason A. Duff State Bar No. 24059696 jasonaduff@hotmail.com Attorney for Vernon Cooks, Jr. CERTIFICATE OF SERVICE This is to certify that on December 4, 2017, a true and correct copy of the above and foregoing document was served on the County District Attorney's Office, Hunt County, by electronic service through the Electronic Filing Manager. Jason A. Duff