Tahronda Shanell White v. State

ACCEPTED 07-15-00348-CR SEVENTH COURT OF APPEALS AMARILLO, TEXAS 11/18/2015 9:58:28 AM Vivian Long, Clerk APPELLATE NO. 07-15-00348-CR TAHRONDA SHANELL WHITE § IN THE COURT OF APPEALS FILED IN § 7th COURT OF APPEALS V. § OF THE SEVENTHAMARILLO, SUPREMETEXAS § 11/18/2015 9:58:28 AM STATE OF TEXAS § JUDICIAL DISTRICT VIVIAN LONG CLERK MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW TAHRONDA SHANELL WHITE, Appellant, by and through her counsel, David Crook, and files this motion for an extension of 30 days in which to file the Appellant’s Brief. In support of this motion, Appellant would show the Court the following: I. The Appellant was convicted in the County Court of Terry County, Texas, of the offense of Theft of Property in Cause No. 29906, styled State of Texas v. Tahronda Shanell White. The Appellant was assessed a punishment of confinement in County Jail for 6 months and a $2,000 fine. II. The deadline for filing the appellate brief is November 30, 2015. Counsel for Appellant has not requested any extensions prior to this request. III. Appellant's request for an extension is based upon the following facts: Counsel has been spending some time in Shreveport, Louisiana, as Counsel’s 88-year old mother requires some attention to her affairs regarding her increasing hearing and vision problems. Prayer 2 WHEREFORE, appellant prays the Court grant this motion and extend the deadline for filing the Appellant’s brief in Appellate No. 07-15-00348-CR to Wednesday, December 30, 2015. Respectfully submitted, Crook & Jordan By: /s/David Crook David Crook PO Box 94590 Lubbock, TX 79493 SBN: 05109530 Telephone: (806) 744-2082 Fax: (806) 744-2083 E-Mail: dcrook@nts-online.net Attorney for Appellant CERTIFICATE OF SERVICE This is to certify that a copy of the above-entitled and numbered motion has been served on Jo’Shae Ferguson Worley, attorney for the state, at the office of the District Attorney of Terry County, by e-mail on this the 18th day of November, 2015. /s/David Crook__________ DAVID CROOK ATTORNEY FOR APPELLANT