Daniel Wayne McLemore v. State

ACCEPTED 12-14-00314-CR; 12-14-00315-CR; 12-14-316-CR; 12-14-00317-CR; 12-14-00318-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 9/14/2015 2:07:08 PM Pam Estes CLERK NO. 12-14-00314-CR; 12-14-00315-CR; 12-14-00317-CR; DANIEL WAYNE MCLEMORE. § IN THE TWELFTH COURT OF FILED IN Appellant, § 12th COURT OF APPEALS § TYLER, TEXAS § 9/14/2015 2:07:08 PM VS. § APPEALS IN AND FOR PAM ESTES § Clerk § THE STATE OF TEXAS, § Appellee. § THE STATE OF TEXAS MOTION TO EXTEND TIME TO FILE AMENDED APPELANT BRIEF TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW DANIEL WAYNE MCLEMORE, by and through his attorney, Wm. Brandon Baade, and makes this MOTION TO EXTEND TIME TO FILE AMENDED APPELANT BRIEF: 1. The deadline for filing the AMENDED APPELANT’s Brief is September 1, 2015. 2. APPELANT seeks and extension of fourteen (30) days from the date of filing this motion or October 14, 2015 to file AMENDED APPELANT’s Brief. 3. Facts relied on to reasonably explain the need for an extension: 4. I have not found the notice requiring an Amended Brief in these cases in my email, although I have never had an issue receiving them. I did receive an email letting me know I was late filing an Amended Brief in the above cases. 5. Since the cases were consolidated I intended that the error argued in the originally filed Appellant Brief to cover all of the cases, even though the trial court did not assign the cases one cause number upon consolidation. 6. I will need to get the reporters and Clerk’s record from the Wood County District Clerk to prepare an Amended Brief. 7. APPELANT has been granted zero (0) extension of time to file the Amended Appellant Brief. WHEREFORE, DANIEL WAYNE MCLEMORE, by his attorney, Wm. Brandon Baade, requests the court extend time to file AMENDED APPELANT’s Brief in this case. RESPECTFULLY SUBMITTED, Wm. Brandon Baade 522 N Broadway Ave Tyler, TX 75702 Tel: (903) 526-5867 brandonbaadelaw@gmail.com _______________________________ Wm. Brandon Baade State Bar No. 00793189 Attorney for Appelant CERTIFICATE OF CONFERENCE I certify that I have contacted Tom Burton, Attorney for Appellee, in this case and he is in agreement with this motion. _______________________________ Wm. Brandon Baade State Bar No. 00793189 Attorney for Appellant CERTIFICATE OF SERVICE I, the undersigned, hereby certify that a true and correct copy of the foregoing MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF was served on all counsel of record by U.S. Mail on September 14, 2015. _______________________________ Wm. Brandon Baade State Bar No. 00793189 Attorney for Appellant