ACCEPTED
06-14-00230-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
3/24/2015 11:49:12 AM
DEBBIE AUTREY
CLERK
NO. 06-14-00230-CR
_______________________________________________________
FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
IN THE SIXTH DISTRICT COURT OF APPEALS
3/24/2015 11:49:12 AM
TEXARKANA, TEXAS DEBBIE AUTREY
Clerk
_______________________________________________________
NICK FEIZY,
Appellant,
v.
STATE OF TEXAS,
Appellee.
_______________________________________________________
APPELLANT’S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
_______________________________________________________
TO THE HONORABLE COURT OF APPEALS:
1. Appellant’s Brief is due on April 9, 2015. Appellant seeks a 30-day
extension to make the brief due on May 9, 2015.
2. This is the first request for an extension.
3. The undersigned counsel knows this Court expects attorneys to file
briefs when they are due. This is an exceptional case. The undersigned, a sole
practitioner, has briefs on the merits in two separate cases before the Supreme
MOTION FOR EXTENSION
PAGE 1
Court of Texas, due on April 6 (No. 14-0591) and April 9 (No. 14-0732),
respectively. This is in addition to counsel’s usual March workload (which
included a motion for rehearing in the Texas Supreme Court, two oral arguments,
an Appellant’s Brief, a federal 12(b)(6) motion, a federal summary judgment
response, and error preservation research in preparation for a March 30 trial
setting). Preparing the two merits briefs for the Supreme Court has, quite simply,
overwhelmed counsel.
4. Appellee does not oppose this motion.
Based on the foregoing, Appellant asks that the deadline to file his brief be
extended to May 9, 2015.
Respectfully submitted,
/s/Charles “Chad” Baruch
The Law Office of Chad Baruch
Texas Bar Number 01864300
3201 Main Street
Rowlett, Texas 75088
Telephone: (972) 412-7192
Facsimile: (972) 412-4028
E-Mail: baruchEsq@aol.com
Attorney for Appellant
MOTION FOR EXTENSION
PAGE 2
CERTIFICATE OF CONFERENCE
The undersigned certifies that he conferred with John Rolater, counsel for
appellee, who stated that he does not oppose the relief sought by this motion.
/s/Charles “Chad” Baruch
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of this instrument was
served upon all counsel of record by e-filing and by email to jrolater@co.collin.tx.us
on March 24, 2015.
/s/Charles “Chad” Baruch
MOTION FOR EXTENSION
PAGE 3