ACCEPTED
06-15-00168-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
12/16/2015 3:34:25 PM
DEBBIE AUTREY
CLERK
NO. 06-15-00168-CR
IN THE COURT OF APPEALS FILED IN
6th COURT OF APPEALS
FOR THE SIXTH APPELLATE DISTRICT TEXARKANA, TEXAS
AT TEXARKANA 12/16/2015 3:34:25 PM
DEBBIE AUTREY
Clerk
LEON HILL
VS.
THE STATE OF TEXAS
APPEALED FROM THE 4TH DISTRICT COURT, RUSK COUNTY, TEXAS
TRIAL CAUSE NO. CR 14-313
FIRST MOTION FOR EXTENSION OF TIME
TO FILE BRIEF FOR LEON HILL, APPELLANT
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW LEON HILL, and pursuant to Rule 10.5(b), TEX.
R. APP. PROC., and pursuant to the extension policies of this
Court, makes this request to extend filing the brief in this cause
and would show as follows:
I.
The Official Court Reporter has filed the Reporter’s record with
this Honorable Court. The undersigned has received copies of
that record as well as the Clerk’s Record. The deadline for filing
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Appellant’s Brief is on or before December 21, 2015.
II.
Appellant requests an additional thirty (30) days in which
to complete the research and writing necessary for submission
of the brief.
III.
As reasonable explanation for the need for an extension of
time Appellant would show as follows:
While counsel for Appellant has devoted time to reading
the record, research, and drafting the Brief, the Brief is not yet
finished.
Appellate counsel has also during the past thirty days
devoted his time to other matters in his office, including, but
not limited to, the following matters:
Work on Criminal Appeals
Working on briefs in these cases:
Casey Jones v. State, No. 06-15-00113-CR
Brendan X. Douglas v. State, No. 06-15-00067-CR
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Preparing and Filing a Petition for Discretionary Review in this
case:
Derek Clinton Ward v. State, PD-1573-15
Work on Civil Appeals
Preparing and filing a Petition for Review in:
In the Interest of D.G., K. G., H. M. G., Children, on behalf of
Bennie G., Supreme Court of Texas Docket No. 15-0919
Perfecting Appeal in “In the Interest of K.O, A.O. and O.O.”
Cause No. 06-15-00100-CV.
Probate & Estate Work (All in Gregg County)
Cause No. 2014-0317-P In re Estate of Baker: conference
with counsel
Cause No. 2015-0297-E In re Estate of Roberts: conference
with counsel
Cause No. 2015-0352-E, In re Guardianship of Tommie
Johnson: interview ward, prepare pleadings and report, attend
hearing on temporary guardianship
Child Protective Services Work (All in Gregg County)
CPS conferences, court hearings, correspondence in the
following cases:
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No. 2015-1190-CCL2, “Interest of G. O.”
No. 2015-369-DR, “Interest of D. W. and K. W.”
No. 2015-2162-DR, “Interest of C. Z. Y.”
No. 2015-1171-CCL2, “Interest of C.F.”
No. 2013-955-DR, “Interest of A. T.”
No. 2014-2343-DR, “Interest of J. L. B.”
No. 2014-873-DR, “Interest of J. K. V.”
No. 2014-873-DR-1, “Interest of K. V.”
Counsel has also spent several hours in conference during
each week of the past 30-day period with clients who have
consulted with counsel on such diverse areas of law as
collections, criminal law, probate, juvenile, and other legal
matters.
With a grant of an additional thirty days Appellate counsel
plans to make substantial progress in further reading of the
record and in the writing and research on the brief.
IV.
There has previously been no motion filed for extension of
time, or grants of time extended to Appellant, for the filing of
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Appellant's brief.
WHEREFORE, PREMISES CONSIDERED, LEON HILL, Appellant,
respectfully requests that this Honorable Court of Appeals will,
upon reviewing this Motion, grant the extension of time for filing
Appellant's brief as requested herein, and for such other relief to
which Appellant may be entitled.
Respectfully submitted,
LAW OFFICES OF LEW DUNN
_/s/ Lew Dunn_
Lew Dunn Attorney at Law
201 E. Methvin, Suite 102
P.O. Box 2226
Longview, Texas 75606
TEL. 903-757-6711
FAX 903-757-6712
Texas State Bar No. 06244600
ATTORNEY FOR APPELLANT
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the
foregoing “First Motion for Extension of Time to File Brief for Leon
Hill, Appellant” has been sent by electronic transmission to the
following on this 16th day of December, 2015:
Hon. Zack Wavrusa, Assistant Criminal District Attorney, Rusk
County, Texas, at his e-mail address: zwavrusa@co.rusk.tx.us.
__/S/ Hough-Lewis Dunn
Hough-Lewis (“Lew”) Dunn
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