ACCEPTED
14-15-00589-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
12/22/2015 10:29:56 PM
CHRISTOPHER PRINE
CLERK
NO. 14-15-00589-CR
IN THE COURT OF APPEALS FOR THE FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
FOURTEENTH DISTRICT OF TEXAS 12/22/2015 10:29:56 PM
CHRISTOPHER A. PRINE
AT HOUSTON Clerk
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NO. 13CR1806
IN THE 212th DISTRICT COURT OF
GALVESTON COUNTY, TEXAS
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ROYCE GENE ADAMS, III, APPELLANT
V.
THE STATE OF TEXAS, APPELLEE
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MOTION FOR FOURTH EXTENSION OF
TIME TO FILE BRIEF OF APPELLANT
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Winston E. Cochran, Jr.
Attorney at Law
Texas Bar No. 04457300
P.O. Box 2945
League City, TX 77574
Tel. (713) 228-0264
E-mail:winstoncochran@comcast.net
Counsel for Appellant
TO THE HONORABLE COURT OF APPEALS:
COMES NOW the appellant, Royce Gene Adams, III (hereinafter “Adams”),
through the undersigned counsel, and respectfully requests that this Court grant a
fourth, short extension of the time to file the appellant’s brief, until December 31,
2015, for reasons set forth as follows.
1. Adams was indicted for two counts of Aggravated Sexual Assault,
allegedly committed against a child. A jury found Adams guilty as charged on each
count. Punishment was assessed at confinement for forty-five years in the Texas
Department of Criminal Justice, Correctional Institutions Division, plus a fine, on
Count One. Punishment was assessed at confinement for life, plus a fine, on Count
Two.
2. Adams gave timely notice of appeal on both counts. Adams also is
appealing convictions on two counts in another case, as addressed in a separate
motion for extension.
3. The appellant’s brief is due on December 22, 2015, pursuant to a third
extension of time to file the brief. The appellant requests a short, fourth extension.
4. The reasons for the requested extension are as follows:
A. The undersigned counsel has decided to scale down the brief by
abandoning certain issues relating to the guilt stage of trial. Counsel
came to this conclusion very late in the process, and with some
trepidation, but not everything that was questionable at trial makes a
good appellate point. The key issue now will concern a
punishment-stage jury charge request and will apply to all of the counts
at issue in both cases. Counsel simply has not time, by the present due
date, to make the needed structural revisions and to beef up the
argument of the charge issue to counsel’s satisfaction.
B. Unfortunately access to resources will be limited from mid-day on
December 23 through December 27 because of the Christmas holiday
period. Accordingly, counsel believes some time in the week following
Christmas is needed.
Wherefore Adams prays that the time for filing the appellant’s brief in this
cause be extended to December 31, 2015.
Respectfully submitted,
/s/ Winston E. Cochran, Jr.
Winston E. Cochran, Jr.
Attorney at Law
Texas Bar No. 04457300
P.O. Box 2945
League City, TX 77574
Tel. (713) 228-0264
E-mail:winstoncochran@comcast.net
Counsel for Appellant
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CERTIFICATE OF SERVICE
I certify that a copy of this motion for extension will be served on counsel for
the State at the following address on December 23, 2015:
Galveston County District Attorney’s Office
Appellate Division
600 59th Street
Galveston, TX 77551
/s/ Winston E. Cochran, Jr.
Winston E. Cochran, Jr.
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Royce Gene Adams III v. State
Combined Opinion