ACCEPTED
02-17-00252-CR
SECOND COURT OF APPEALS
FORT WORTH, TEXAS
12/19/2017 5:24 PM
DEBRA SPISAK
CLERK
IN THE COURT OF APPEALS
FOR THE SECOND COURT OF APPEALS DISTRICT
FORT WORTH, TEXAS
FILED IN
2nd COURT OF APPEALS
KEVIN E. BROMLEY § FORT WORTH, TEXAS
APPELLANT § 12/19/2017 5:24:40 PM
§ DEBRA SPISAK
VS. § NO: 02-17-00252-CR Clerk
§
THE STATE OF TEXAS §
APPELLEE §
APPELLANT=S MOTION FOR EXTENSION
OF TIME FOR FILING APPELLANT=S BRIEF
NOW COMES, KEVIN E. BROMLEY, Appellant, by and through his attorney, WES BALL,
and requests that he be granted an extension of time for filing his brief in the above-styled and
numbered cause. As grounds for granting this motion, Appellant states:
The undersigned counsel is responsible for filing the Appellant=s brief in this case.
Appellant seeks an extension of sixty (60) days to February 18, 2018. Appellant=s
counsel seeks the extension due to a need for this additional time to adequately
prepare Appellant=s brief. Due to his caseload in both trial and appellate courts, he
has been unable to complete the brief.
Appellant=s brief is currently due on December 20, 2017. The judgment in this cause
was entered on July 20, 2017 by the trial judge presiding in the Criminal District
Court No. 3 of Tarrant County, Texas. Appellant was convicted of AGG ASSAULT
DEADLY WEAPON. Appellant was sentenced to six (6) years confinement in the
Institutional Division of the Texas Department of Criminal Justice, probated for 72
months. Appellant is currently out of jail on an appeal bond. Notice of Appeal was
entered on July 25, 2017. The cause number in the trial court was 1469526. No
extensions of time have been previously granted in this cause. Counsel requests an
extension of sixty (60) days. Granting this extension should not cause any delay in
the present submission date. Appellant=s counsel is aware of the policy concerning
deadlines for filing briefs and the reluctance to grant extensions in the ordinary case.
This request is not being made for mere purposes of delay, but so that justice may be
done.
APPELLANT’S MOTION FOR EXTENSION OF TIME FOR FILING APPELLANT’S BRIEF PAGE 1 OF 2
WHEREFORE PREMISES CONSIDERED, Appellant prays that this Honorable Court
grant an extension of sixty (60) days for filing his brief on appeal to February 18, 2018.
Respectfully submitted,
/s/ Wes Ball
WES BALL
State Bar No. 01643100
4025 Woodland Park Blvd., Suite 100
Arlington, Texas 76013
Email: WBnotices@ballhase.com
Telephone: (817)860-5000
Fax No.: (817)860-6645
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
On this the 19th day of December, 2017, a true and correct copy of the above and foregoing
Appellant=s Motion for Extension of Time for Filing Appellant=s Brief was delivered electronically to
the Post-Conviction Division of the Tarrant County District Attorney=s Office.
/s/ Wes Ball
WES BALL
Attorney for Appellant
CERTIFICATE OF CONFERENCE
On the 18th day of December, 2017, Malinda Davis, assistant to Appellant=s counsel
contacted Cyndi Burgess, assistant to Debra Windsor, Chief of Post-Conviction, Tarrant County
District Attorney=s Office regarding the foregoing Motion and has been advised that the state does
not oppose the Motion.
/s/ Wes Ball______________________________
WES BALL
APPELLANT’S MOTION FOR EXTENSION OF TIME FOR FILING APPELLANT’S BRIEF PAGE 2 OF 2