ACCEPTED
12-15-00176-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
10/29/2015 3:13:13 PM
Pam Estes
CLERK
NO. 12-15-00176-CR
ON APPEAL FROM THE 217TH JUDICIAL DISTRICT COURTFILED IN
ANGELINA COUNTY, TEXAS 12th COURT OF APPEALS
TYLER, TEXAS
CAUSE NO. 2014-0568 10/29/2015 3:13:13 PM
PAM ESTES
TH Clerk
RANDY EARL CRAWFORD § IN THE 12 COURT OF APPEALS
§
§ OF
vs. §
§
STATE OF TEXAS § TYLER, TEXAS
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Randy Earl Crawford, 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 217th District Court of Angelina
County, Texas.
2. The case below was styled the STATE OF TEXAS vs. Randy Earl
Crawford, and numbered 2014-0568. Appellant was convicted Theft.
4. Appellant was assessed a sentence of Fifteen (15) years in Texas
Department of Criminal Justice Institutional Division on June 25, 2015.
5. Notice of appeal was given on June 26, 2015.
6. The clerk's record was filed on August 24, 2015; the reporter's record
was filed on July 7, 2015.
7. The appellate brief was presently due on October 23, 2015.
8. Appellant requests an extension of time of thirty (30) days from the
current due date.
9. One extension to file the brief has been received in this cause.
10. Defendant is currently incarcerated.
11. Appellant relies on the following facts as good cause for the requested
extension:
Counsel was recently hospitalized due to a stroke and has just recently
returned to the office full time. The current court appointment appeal caseload will
make it difficult to complete the appeal and counsel is asking for an additional 30
days.
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:
/s/John D. Reeves
____________________
John D. Reeves
Attorney at Law
1007 Grant
Lufkin, Texas 75901
Phone (936) 632-160
Fax: (936) 632-1640
tessabellus@yahoo.com
SBOT # 16723000
Counsel for Appellant
CERTIFICATE OF CONFERENCE
Pursuant to Tex. R. App. 10.1 (5), certify that I, the undersigned conferred
with opposing counsel who is not opposed to an extension.
/s/John D. Reeves
___________________________
John D. Reeves
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing Appellant’s
Motion to Extend Time to file Appellant’s Brief on this 29th day of October, 2015
forwarded to State’s Attorney, April Ayers-Perez, Angelina County, by electronic
service at aprerez@angelinacounty.net.
/s/John D. Reeves
__________________________
John D. Reeves
Attorney for Appellant,
David Charles Dailey