ACCEPTED
05-18-00064-CR
FIFTH COURT OF APPEALS
DALLAS, TEXAS
1/30/2018 4:58 PM
LISA MATZ
CLERK
CASE NO. 05-18-00064-CR
IN THE FIFTH COURT OF APPEALS
FILED IN
5th COURT OF APPEALS
DALLAS, TEXAS DALLAS, TEXAS
1/30/2018 4:58:31 PM
__________________________________________________________________
LISA MATZ
Clerk
QUINCY BLAKELY, Appellant
V.
THE STATE OF TEXAS, Appellee.
__________________________________________________________________
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S JURISDICTIONAL LETTER BRIEF
________________________________________________________________
Quincy Blakely
2701 Little Elm Parkway Ste. 100-551
Little Elm, Texas
TO THE HONORABLE FIFTH COURT OF APPEALS:
NOW COMES Quincy Blakely, Appellant herein, hereby moves this Court to extend
briefing schedule in this proceeding. In support of this motion, Appellant would show as follows:
1. This Court advised the parties on January 23, 2018 to file a jurisdictional letter brief, and
Appellant’s deadline for filing said jurisdictional letter brief in this matter is January 31,
2018 and Appellee’s deadline is February 9, 2018.
2. However, Appellant is seeking counsel in the preparation of the jurisdictional letter
matters and hereby request an extension to properly respond.
3. In light of seeking counsel, and due to the short notice provided for preparing and filing
this jurisdictional brief, Appellant has not yet had an adequate opportunity to properly
prepare the brief to be considered by this Court, and thus, seeks an extension of time to
be able to prepare a cogent and succinct brief to aid this Court in its analysis of the
jurisdictional issues presented, which relate to this Court’s jurisdiction to entertain an
appeal after a Motion to Dismiss for Lack of Subject Matter and Personal Jurisdiction
which was denied.
4. The State of Texas would not suffer any undue hardship or other prejudice as a result of
an extension in the present case. This request is sought not for delay, but so that
justice may be done.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully moves this Court to
grant the requested Appellant’s First Motion to Extend Time to File Appellant’s
Jurisdictional Letter Brief and reschedule this matter so as to allow Appellant to properly
present his brief to This Court, and to grant any and all relief to which Appellant may be
entitled in law or equity.
/s/ Quincy Blakely
2701 Little Elm Parkway #100-551
Little Elm, Texas
blakelyrightsreserved@gmail.com
CERTIFICATE OF SERVICE
I hereby certify that a copy of this Notice of Appeal was served upon the Dallas County District
Attorney’s Office via https://efile.txcourts.gov.
/s/ Quincy Blakely