ACCEPTED
06-14-00208-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
4/27/2015 4:39:59 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00208-CR
FILED IN
6th COURT OF APPEALS
STATE OF TEXAS § IN THE TEXARKANA, TEXAS
§ 4/27/2015 4:39:59 PM
VS. § 6TH COURT DEBBIE AUTREY
§ Clerk
TONY DEWAYNE CRAYTON § OF APPEALS
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Tony Dewayne Crayton, 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 8th Judicial District Court of Hopkins
County, Texas.
2. The case below was styled the STATE OF TEXAS vs. Tony Dewayne
Crayton, and numbered 1323670.
3. Appellant was convicted of Murder.
4. Appellant was assessed a sentence of 50 years on November 24, 2014.
5. Notice of appeal was given on November 24, 2014.
6. The clerk's record was filed on March 26, 2015; the reporter's record
was filed on January 27, 2015.
7. The appellate brief is presently due on April 27, 2015
8. Appellant requests an extension of time of 45 days from the present
date, i.e. June 11, 2015.
9. No 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:
A. Appellant’s case raises many areas of appellate consideration
many of which are quite complex.
B. Appellant’s attorney was unable to devote sufficient time to
prepare Appellant’s Brief due to extensive time in court appearing
on the following dates and cases:
1. 4/2/15 - 8th Judicial District Court of Rains County: State of
Texas v. Jeremy Ratliff, State of Texas v. Christopher
Morrison, In the Matter of Terry McCollum, a child;
2. 4/8/15 - Franklin County Court: State of Texas v. Martin
Flores, Cause No. 12898, State of Texas v. Norman Ball, Cause
No. 12907; Justice Court of Hopkins County: Christopher
Hyche Cause No. 1520162;
3. 4/9/15 – Hopkins County Court at Law: State of Texas v.
Kendrick Moseley, Cause No. 1401429; 8th Judicial District
Court of Hopkins County: State of Texas v. Robert Dyer, Cause
No. 1424287, State of Texas v. Jacob Robinson, Cause No.
1323373 and 1323339, State of Texas v. Kody Williams, Cause
No. 1424144;
4. 4/13/15 - 8th Judicial District Court of Hopkins County: State
of Texas v. Jordan Delapaz, Cause No. 1524486, State of Texas
v. Tony Thomas, Cause No. 1021501, 1021502, 1021894,
1021895, 1021896, State of Texas v. Kody Williams, Cause
No. 1424144;
5. 4/15/15 - 8th Judicial District Court of Hopkins County: State
of Texas v. Donald Detwiler, State of Texas v. Frances Ethridge
Cause No. 1424122;
6. 4/16/15 – Hunt County District Court: State of Texas v.
Christopher Howard Cause No. 29926;
7. 4/17/15 - 8th Judicial District Court of Franklin County: State
of Texas v. James Crawford, State of Texas v. Daniel Wetzel
Cause No. F-8919, F-8920, State of Texas v. Charles Derrick
Cause No. F-8954, State of Texas v. David Dollins Cause No.
F-8840, State of Texas v. Mary Ann Johnson Cause No.
F-8844, State of Texas v. Kimberly Otis Cause No. F-8870;
8. 4/21/15 - 8th Judicial District Court of Hopkins County: State
of Texas v. Raymond Collins Cause No. 1223038;
9. 4/23/15 - Hopkins County Court at Law: State of Texas v.
Arnaud Crouzet, Cause No. CR1431009, 8th Judicial District
Court of Hopkins County: State of Texas v. Tallan Askew,
Cause No. 1424015, 1424016, State of Texas v. Gary Ross, In
the Matter of Deanthony Moore, a child, Cause No. J01631;
10.4/24/15 - 8th Judicial District Court of Delta County: State of
Texas v. Joseph Tubb, Cause No. 7417;
11.4/27/15 – Wood County District Court: State of Texas v.
Krystal Prescher, Cause No. 20621-2009;
C. Further, Appellant’s attorney prepared and filed an Appellant’s
Brief in the 6th Court of Appeals, Appellate No. 06-14-00110-CR,
Cody Thomas v. The State of Texas on 4/26/15.
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,
Martin Braddy Attorney at Law
121 Oak Avenue
Suite A
Sulphur Springs, Texas 75482
Tel: (903) 885-2040
Fax: (903) 500-2704
By: /s/ Martin Braddy
Martin Braddy
State Bar No. 00796240
martin.braddy@verizon.net
Attorney for Tony Dewayne Crayton
CERTIFICATE OF SERVICE
This is to certify that on April 27, 2015, a true and correct copy of the above
and foregoing document was served on the District Attorney's Office, Hopkins
County, 110 Main Street Sulphur Springs, Texas 75482, by E-mail.
/s/ Martin Braddy
Martin Braddy