Billy Joe Selman v. State

Opinion

ACCEPTED

06-15-00121-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

9/18/2015 1:08:21 PM

DEBBIE AUTREY

CLERK

NO. 06-15-00121-CR

FILED IN

BILLY JOE SELl\1AN § IN THE 6th COURT OF APPEALS § TEXARKANA, TEXAS

VS. § SIXTH COURT 9/18/2015 1:08:21 PM DEBBIE AUTREY

§ Clerk STATE OF TEXAS § OF APPEALS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes BILLY JOE SELMAN, Appellant in the above styled and numbered cause, and moves this COUli to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following:

1. This case is on appeal from the County Court at Law of HILL County, Texas.

2. The case below was styled as STATE OF TEXAS vs. BILLY JOE SELMAN, and numbered M0890-14.

3. Appellant was convicted of Evading Arrest or Detention.

4. Appellant was assessed a sentence eight months in the Hill County Law ntorcemeltlt ~"lH""l on l\rlay 1 15.

on 15.

7. The appellate brief is presently due on September , 2015.

8. Appellant requests an extension of time of 60 days from the present date, i.e. November 24,2015.

9. No extension to file the brief has been received in this cause.

10. Defendant is currently in custody and has a pending Felony charge.

11. Appellant relies on the following facts as good cause for the requested extension:

Counsel has just completed two Felony trials in Johnson County and IS

preparing for two other felony trial cases and one misdemeanor trial.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this Motion To Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate.

Respectfully submitted,

RICARDO DELOSSANTOS

202 S. MAIN

CLEBURNE, TX 76033

Tel: (817) 558-3885

Fax: (817) 641-2525

Santos

CERTIFICATE OF SERVICE

This is to certify that on September 18, 2015, a true and correct copy of the above and foregoing document was served on the County Attorney's Office, Hill County, by fax.

Ricardo De Los Santos

STATE OF TEXAS § §

COUNTY OF JOHNSON §

AFFIDAVIT

BEFORE ME, the undersigned authority, on this day personally appeared Ricardo De Los Santos, who after being duly sworn stated:

"I am the attorney for the appellant in the above numbered and entitled cause. I have read the foregoing Motion To Extend Time to File Appellant's Brief and swear that all of the allegations of fact contained therein are true and correct"

lsi Ricardo De Los Santos Ricardo De Los Santos

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME on ~"-----, 201 to ce11ifY which witness my hand and seal of office.

Notary Public, State of Texas