ACCEPTED
09-17-00060-CR
NINTH COURT OF APPEALS
BEAUMONT, TEXAS
12/13/2017 5:05 PM
CAROL ANNE HARLEY
CLERK
NO:09-17-00060-CR
TRIAL COURT CASE NO(s) 12519
FILED IN
COURT OF APPEALS 9th COURT OF APPEALS
NINTH DISTRICT BEAUMONT, TEXAS
BEAUMONT, TEXAS 12/13/2017 5:05:13 PM
CAROL ANNE HARLEY
JOSEPH LEWIS § APPEAL FROM Clerk
THE 1-A DISTRICT
§ COURT
§
vs. § OF
§
THE STATE OF TEXAS, APPELLEE § TYLER COUNTY, TEXAS
MOTION TO EXTEND THE TIME
FOR FILING APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
COMES NOW the Appellant and moves the Court for an extension of time to file a
Appellant’s brief in the cause, and in support thereof would show the Court as follows:
I.
On January 9th , 2009, the Appellant plead Guilty, to the offense of Aggravated Sexual
Assault of a Child. On February 9th, 2017, he was found guilty by jury verdict, and was sentenced
on February 9th, 2017, to a Life sentence in the Texas Department of Criminal Justice, under Cause
No. 12,519; THE STATE OF TEXAS VS. JOSEPH CHRISTOPHER LEWIS; IN THE 1-a
DISTRICT COURT OF TYLER COUNTY, TEXAS. THE STATE OF TEXAS VS. JOSEPH
LEWIS; IN THE 1-A DISTRICT COURT OF TYLER, TEXAS.
II.
The Appellant timely filed his Notice of Appeal and the Transcript and Statement of Facts
were timely filed herein, and the Appellant’s Brief was due to be filed herein on December 13th,
2017. III.
Appellant respectfully requests that this Honorable Court grant an additional extension of
approximately thirty (30) days or until January 12th, 2018, in filing Appellant’s Brief
IV.
The such extension is necessary for the following reasons:
1. Counsel makes this request for extension because he has been scheduled in multiple
counties on the felony trial dockets in Jefferson, Hardin, Liberty, Newton, and Tyler Counties, for
announcement, pretrial and trial dockets. Counsel has been heavily scheduled on the Hardin County
Dockets, in both the 356th and 88th Judicial District Courts. Counsel sincerely apologizes to this
honorable court for filing an additional extension and wishes to remain in good standing with this
Honorable Court, but he prays that the court will grant this second extension to allow the needed
time to finalize and file Appellant’s Brief to ensure accuracy and eliminate the possibility of error.
2. As well, counsel respectfully informs the court he has been working on several other
briefs, (in the Ninth Court of Appeals), writs and petitions for discretionary review, during this time
of which have required more than the usual amount of time in research and reviewing case law.
3. Counsel informs the court this extension is not sought for delay, but that justice may
be done.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests and prays
that this Honorable Court extend the time for the filing of Appellant’s Brief herein approximately
on January 12th, 2018.
Respectfully submitted,
/s/ Bryan S. Laine
Bryan S. Laine
TBN. #24011488
1045 S. Redwood
Kountze, Texas 77625
Tel: (409) 246-4008
Fax: (409) 246-3645
bryanlaine@gt.rr.com
CERTIFICATE OF SERVICE
I hereby certify that true and correct copy of the foregoing document has been forwarded
to all opposing counsel and parties on this the 13th day of December 2017.
By:/s/ Bryan S.Laine
/s/Bryan S. Laine
State Bar No. 24011488
NO:09-17-00060-CR
TRIAL COURT CASE NO(s) 12,519
COURT OF APPEALS
NINTH DISTRICT
BEAUMONT, TEXAS
JOSEPH LEWIS § APPEAL FROM THE 1-A DISTRICT
§ COURT
§
vs. § OF
§
THE STATE OF TEXAS, APPELLEE § HARDIN COUNTY, TEXAS
ORDER
On________________________, 2017, came on to be considered JOSEPH LEWIS’S
Appellant’S Motion to Extend the Time For Filing Appellant’s Brief and said motion is hereby:
(Granted) (Denied)
JUDGE PRESIDING