ACCEPTED
01-15-00642-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
10/22/2015 2:20:36 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00642-CR
IN THE COURT OF APPEALS FILED IN
FOR THE 1st COURT OF APPEALS
HOUSTON, TEXAS
FIRST SUPREME JUDICIAL DISTRICT OF TEXAS
10/22/2015 2:20:36 PM
AT HOUSTON
CHRISTOPHER A. PRINE
_______________________________________________________Clerk
ALVIN PERRY JONES
Appellant
v.
THE STATE OF TEXAS,
Appellee
_______________________________________________________
Appeal from Cause No. 13CR2725
In the 405th District Court of
Galveston County, Texas
__________________________________
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
BRIEF FOR APPELLANT
_________________________________
To the Honorable Justices of the Court of Appeals:
Appellant, ALVIN PERRY JONES, by and through his Counsel of Record,
JARED ROBINSON, files this Unopposed Motion to Extend Time to File Brief and in
support shows this Court the following:
I.
Appellant was convicted one count of Aggravated Robbery on June 24, 2015. The
jury assessed punishment at 35 years incarceration in the Texas Department of Criminal
Justice.
On November 21, 2013, the Galveston County Grand Jury returned an enhanced
indictment of True Bill. A jury trial was held beginning on June 22nd, 2015. The jury
found the defendant guilty on June 24th, 2015 and sentenced the defendant to Thirty-Five
(35) years imprisonment in the Texas Department of Criminal Justice on the same day.
II.
Appellant’s brief is due on or before October 22, 2015. Appellant’s counsel
respectfully requests an extension for at least sixty days to file Appellant’s brief. The
Assistant District Attorney handling the case, Rebecca Klaren, has indicated the State of
Texas is unopposed to Appellant’s request for an extension.
Appellant’s counsel needs additional time to complete his brief and additional
time to review the Reporter’s Record because of conflicts created by work in other cases.
More specifically, counsel for Appellant has been in trial in the 405th Dictrict Court in
Galveston County, representing a client who has been charged with two First Degree
Felonies. Counsel also has numerous other cases set for trial in the months of October
and November in Galveston and Brazoria Counties. This is the first request for an
extension of time filed with this Court. Therefore Counsel requests that this Court extend
the time to file Appellant’s Brief until at least December 21st, 2015.
Respectfully Submitted,
JONES ROBINSON, LLP.
/s/ Jared S. Robinson /s/
JARED S. ROBINSON
State Bar No.: 24060506
1100 Rosenberg Avenue
Galveston, Texas 77550
2
409.765-5705
409.765.7570 Facsimile
ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
I hereby affirm a true and correct copy of the foregoing was delivered via hand-
delivery and/or electronic delivery to Rebecca Klaren, Assistant Galveston County
Criminal District Attorney, on the 22nd day of October 2015.
/s/ Jared S. Robinson
JARED S. ROBINSON
CERTIFICATE OF CONFERENCE
I hereby certify and affirm that I have communicated on the 22nd day of October,
2015 with Rebecca Klaren, Assistant Galveston County Criminal District Attorney,
regarding Appellant’s request for an extension of time to file his brief and she has
indicated that the State of Texas is Unopposed to this request.
/s/ Jared S. Robinson
JARED S. ROBINSON
3