ACCEPTED
06-15-00053-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
8/26/2015 5:52:01 PM
DEBBIE AUTREY
CLERK
IN THE COURT OF APPEALS
Sixth Appellate District
State of Texas FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
MIKEL HALL, 8/27/2015 8:17:00 AM
Appellant DEBBIE AUTREY
Clerk
v. NO. 06-15-00053-CR
Trial Court #2013-F-00107
STATE OF TEXAS,
Appellee
MOTION FOR EXTENSION
OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW Mikel Hall, Appellant, by and through his below named
Attorney and pursuant to Texas Rules of Appellate Procedure, hereby requests
an extension of the time period for the filing of the Appellant’s Brief and in
support of same would show the Court as follows:
I.
A. This case is pending from the 5th Judicial District Court of Cass County,
Texas. The date of the Judgment is March 11, 2015, with sentence being
imposed by the trial court on March 11, 2015.
B. The case was styled, “State of Texas v. Mikel Hall, Cause No.
2013F00107, Count I and Count II.
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C. Appellant was convicted of the offense of Indecency with Child and
Sexual Assault of child.
D. Punishment was assessed by the jury at 15 years in the Institutional
Division of the Texas Department of Criminal Justice.
E. The Appellant’s Brief is due to be filed August 26, 2015.
F. Appellant requests an extension of the filing of Appellant’s Brief of
fifteen days, making the Appellant’s Brief due on September 10, 2015.
G. Appellant’s attorney has been diligent in researching and preparing the
Appellant’s brief for the Court however, due to counsel’s preparation
and attendance for the criminal pre-trial docket in the Circuit Court in
Ashdown, Arkansas on August 4, 2015, and August 11, 2015, hearings in
District Court in Little River County, Arkansas on August 12 and August
19, a contested protective order hearing in the County Court at Law of
Cass County, Texas on August 14, 2015 and family law hearings in
District Court in Bowie County, Texas on August 24, 2015, Appellant’s
counsel has had insufficient time to complete Appellant’s brief.
H. There have been no previous requests for extensions in this cause.
I. Counsel for Appellant has contacted the Assistant Criminal District
Attorney for Cass County, Texas, who is assigned to this matter and she
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has no objection to the request of the Appellant.
II.
Appellant’s attorney has been diligent in pursuing this appeal and is not
seeking this extension for the purpose of delay.
PRAYER
WHEREFORE, on the basis of the Texas Rules of Appellate Procedure,
Appellant’s attorney respectfully requests this Court to grant the Motion for
Extension of Time for the filing of Appellant’s Brief.
Respectfully submitted,
/s/ Alwin A. Smith
Alwin A. Smith
TBN: 18532200
al@alwinsmith.com
602 Pine Street
Texarkana, Texas 75501
903/792-1608
903/792-0899 Fax
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing
Motion for Extension of Time to File Appellant’s Brief has been forwarded to
Ms. Courtney Holland, 604 North Highway 8, Linden, Texas 75563, on this
the 24th day of August 2015.
/s/ Alwin A. Smith
Alwin A. Smith
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