ACCEPTED
06-17-00203-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
6/6/2018 3:01 PM
DEBBIE AUTREY
CLERK
IN THE
COURT OF APPEALS
SIXTH DISTRICT OF TEXAS AT TEXARKANA
FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
NO. 06-17-00203-CR 6/6/2018 3:01:17 PM
DEBBIE AUTREY
Clerk
MARQUIS JAMAL REED, Appellant vs.
THE STATE OF TEXAS, Appellee
MOTION FOR EXTENSION OF TIME TO FILE APPEAL BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW, MARQUIS JAMAL REED, the Appellant in the above entitled and
numbered cause, by and through her attorney of record, Toby C. Wilkinson, and files
her Motion for Extension of Time to File Appeal Brief in the above entitled and
numbered cause, and would show unto this Honorable Court the following:
I.
Movant’s Appeal Brief is due for filing on or before June 6, 2018.
II.
This is Movant’s second request for extension in this cause.
III.
Movant requests an extension of time within which to file his Appeal Brief, and as
reason therefore would show the Court as follows:
Movant would show that his attorney received an extension to file his Brief on or
before June 6, 2018. His attorney inadvertently read the letter as July 6, 2018. The
attorney would show that he was working on a Capital Murder Trial and Jury Selection
begins in July, 2018.
IV.
Attorney would show he discovered this error working on the Brief today when he
discovered this error.
V.
Movant’s attorney would show that the Appellant’s trial was approximately a week
long and the transcript covers numerous volumes.
VI.
The undersigned counsel respectfully requests this Honorable Court to extend
the time of filing of Movant’s Appeal Brief to June 13, 2018.
WHEREFORE, PREMISES CONSIDERED, TOBY C. WILKINSON prays that
this Honorable Court grant Movant's Motion for Extension of Time in this cause.
Respectfully submitted,
Toby C. Wilkinson
Toby C. Wilkinson
Law Office of Toby C. Wilkinson, P.C.
P.O. Box 324
2815 Wesley Street
Greenville, Texas 75403-0324
(903) 454-6096
(903) 454-0446 Fax
SBA #21497300
Attorney for Marquis Jamal Reed,
Appellant
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion for
Extension of Time to File Appeal Brief has been delivered to all attorneys of record this
the 6th day of June 2018.
Toby C. Wilkinson
Toby C. Wilkinson