ACCEPTED
07-15-00181-CR
SEVENTH COURT OF APPEALS
AMARILLO, TEXAS
7/20/2015 5:05:45 AM
Vivian Long, Clerk
NO. 07-15-181-CR
MICHAEL DON DENTON § IN THE COURT OF APPEALS
FILED IN
7th COURT OF APPEALS
§ AMARILLO, TEXAS
v. § OF7/20/2015
TEXAS5:05:45
FOR AM
THE
§ VIVIAN LONG
THE STATE OF TEXAS § SEVENTH JUDICIALCLERK
DISTRICT
MOTION TO EXTEND TIME TO FILE THE
APPELLANT’S BRIEF, BY 45 DAYS
TO THE HONORABLE JUDGES OF THIS COURT:
COMES NOW Michael Don Denton, Appellant in the above-entitled and
numbered cause, and moves the Court to extend time to file the brief by 45 days. In
support thereof, Appellant respectfully shows the Court the following:
I.
Undersigned counsel apologizes to the Court for his neglect of the brief. He
mistakenly assumed the jurisdictional issue raised in this case would be decided
before briefing would begin, and did not keep up with the schedule set by the
Court. No prior extensions have been sought or granted.
II.
The reasons for this request are as follows. In addition to the circumstances
noted in the paragraph above, counsel is currently in London on an annual
international excursion. He is scheduled to return to Amarillo on August 10, 2015.
In addition, counsel would have had insufficient time to prepare the brief
before he left on July 16, 2015. In the thirty days preceding this Motion, counsel
has filed the following extensive documents in addition to representing parole
clients in Lubbock County:
Thomas v. State, 07-14-418/9-CR – opening brief filed 6/29/15
In re R.A.J., 10,253-J#1 (Potter County) – writ application filed 7/10/15
Finch v. State, 07-15-104-CR – opening brief filed 7/15/15
WHEREFORE, the appellant prays the Court extend the time for filing the
brief to August 24, 2015.
Respectfully submitted,
/s/ JOHN BENNETT
John Bennett
P.O. Box 19144
Amarillo, TX 79114
(806) 282-4455
Fax: (806) 398-1988
State Bar Number 00785691
Attorney for the Appellant
appealsattorney@gmail.com
CERTIFICATE OF SERVICE
This is to certify that a copy of the above Motion was served on Warren
Clark, Esq., Randall County Assistant Criminal District Attorney, by email to him
at wclark@randallcounty.org on July 20, 2015.
/s/ JOHN BENNETT
John Bennett
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