ACCEPTED
07-15-00079-CR
SEVENTH COURT OF APPEALS
AMARILLO, TEXAS
9/21/2015 10:44:32 PM
Vivian Long, Clerk
NO. 07-15-00079-CR
KENYA ABDULE MARTIN § IN THE SEVENTH
FILED COURT
IN
7th COURT OF APPEALS
§ AMARILLO, TEXAS
v. § 9/21/2015 10:44:32 PM
§ VIVIAN LONG
THE STATE OF TEXAS § OF APPEALS CLERK
OF TEXAS
MOTION TO EXTEND TIME TO FILE
THE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW Kenya Abdule Martin, appellant, and files this Motion to
extend the time to file his Brief until September 28, 2015.
I.
The appellant’s Brief is due on September 21, 2015. Two prior extensions
have been sought and granted. Undersigned counsel is aware that his previous
motion, filed September 7, 2015, stated it would be his final one in this case;
counsel sincerely apologizes for filing yet another motion.
After counsel filed the second motion, however, a court reporter present at a
pretrial hearing – not the reporter who transcribed the trial – filed a supplemental
volume to the reporters record on September 8, 2015. In addition, this appeal is a
complicated one with several issues to be researched and raised. In light of all this,
undersigned counsel requests the Court’s indulgence for one further week to
properly prepare the appellant’s Opening Brief.
II.
Undersigned counsel further represents the following clients whose briefs or
other appellate pleadings were filed on the indicated dates in the 30 days preceding
the filing of this motion, and has not yet had time to prepare the brief in this case:
Denton v. State, 07-15-181/2-CR – Opening Brief filed 8/27/15
Benefield v. State, 02-14-00099-CR – PDR filed 8/28/15
Finch v. State, 07-15-104-CR – Reply Brief filed 9/3/15
French v. State, 11-14-284-CR – Reply Brief filed 9/3/15
Counsel also represented a prisoner in a parole revocation case in the second week in
September, in Randall County.
WHEREFORE, the appellant prays the Court grant an extension of time to
file the Appellant’s Brief to September 28, 2015.
Respectfully submitted,
/s/ JOHN BENNETT
John Bennett
Post Office Box 19144
Amarillo, Texas 79114
(806) 282-4455
Fax: (806) 398-1988
State Bar Number 00785691
Email: AppealsAttorney@gmail.com
Attorney for the appellant
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CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above Motion was served
by email on September 21, 2015, on Jack Owen, Esq., Assistant District Attorney
for Potter County, to him at jackowen@co.potter.tx.us.
/s/ JOHN BENNETT
John Bennett
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