ACCEPTED
01-14-00895-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
1/12/2015 4:26:53 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00895-CR
In the First Court of Appeals, FILED IN
1st COURT OF APPEALS
Houston, Texas HOUSTON, TEXAS
1/12/2015 4:26:53 PM
CHRISTOPHER A. PRINE
Clerk
LAMAR MARCELL HUNTER
Appellant
v.
THE STATE OF TEXAS
Appellee
Appellant’s First Motion for
Extension of Time to File Brief
Respectfully Submitted by:
Joseph Kyle Verret
THE LAW OFFICE OF KYLE VERRET, PLLC
Counsel for Appellant
TBN: 240429432
11200 Broadway, Suite 2743
Pearland, Texas 77584
Phone: 281-764-7071
Fax: 281-764-7071 Submitted:
Email: kyle@verretlaw.com January 12, 2015
No. 01-14-00895-CR
In the First Court of Appeals,
Houston, Texas
LAMAR MARCELL HUNTER
Appellant
v.
THE STATE OF TEXAS
Appellee
Appellant’s First Motion for
Extension of Time to File Brief
Comes now, Appellant, by and through his undersigned counsel, in the
above styled cause and moves this Honorable Court to extend the time for
the filing of Appellant's Brief. Per Texas Rule of Appellate Procedure
10.5(b), Appellant provides the following:
Current Deadline for Filing: January 12, 2015
Length of Extension Sought: Thirty (30) Days
Number of Previous Extensions Granted: None.
Basis for Extensions:
Appellant's counsel is a solo practitioner with a busy criminal and
juvenile defense caseload, which requires regular appearances in court on
the part of counsel.
In the thirty days since the last motion for extension in this matter,
Appellant’s counsel prepared for an Aggravated Assault with a Deadly
Weapon trial in Cause 1398351, in the 178th District Court of Harris County,
Texas, that was set for trial on December 16, 2014. The matter was
continued but counsel spent the first two weeks of the month of December
preparing for this trial.
Also, in the last thirty days, counsel prepared for and tried a bench trial
on a Motion to Adjudicate Guilt and Revoke probation on a third degree
felony possession of a controlled substance, with an allegation of a new law
violation for Criminal Trespass with a Deadly Weapon, in Cause 12CR2802.
The matter was tried in the 405th District Court of Galveston, Texas on
December 18, 2014.
Counsel then took a week and a half vacation during the holidays from
December 22 to January 31, 2014.
Counsel for Appellant seeks this extension of time to be able to prepare
a cogent and succinct brief to aid this Court in its analysis of the issues
presented. This request is not sought for delay but so that justice may be
done.
All facts recited in this motion are within the personal knowledge of
the counsel signing this motion, therefore no verification is necessary under
Rule of Appellate Procedure 10.2.
PRAYER FOR RELIEF
For the reasons set forth above, Appellant requests that this Court
grant this Appellant’s Second Motion to Extend Time to File Appellant’s
Brief and extend the Deadline for Filing the Appellant’s Brief up to and
including February 11, 2015. Appellant prays all other relief to which he
may be entitled.
Respectfully submitted,
/s/ Joseph Kyle Verret
Joseph Kyle Verret
THE LAW OFFICE OF KYLE VERRET, PLLC
Counsel for Appellant
TBN: 240429432
11200 Broadway, Suite 2743
Pearland, Texas 77584
Phone / Fax: 281-764-7071
Email: kyle@verretlaw.com
Certificate of Service
I certify that a true and correct copy of the foregoing Appellant's First
Motion for Extension of Time to File Brief was served on this 12thth day of
January, 2015 on the Counsel for the Appellee, Rebecca Klaren, at the
Galveston County Criminal District Attorney’s Office by e-service through
electronic filing.
/s/ Joseph Kyle Verret
Joseph Kyle Verret
TBN: 2402932