Brandee Michelle Nichols v. State

Opinion

ACCEPTED

12-14-00287-cr

TWELFTH COURT OF APPEALS

TYLER, TEXAS

2/4/2015 2:05:23 PM

CATHY LUSK

CLERK

IN THE

TWELFTH COURT OF APPEALS

FILED IN

12th COURT OF APPEALS

CAUSE NO. 12-14-00287-CR TYLER, TEXAS 2/4/2015 2:05:23 PM

CATHY S. LUSK

BRANDEE MICHELLE NICHOLS § Clerk THE ON APPEAL FROM

Appellant

VS. § 114TH DISTRICT COURT

THE STATE OF TEXAS, Appellee § SMITH COUNTY, TEXAS

SECOND MOTION FOR EXTENSION OF TIME TO FILE THE APPELLANT’S BRIEF

TO THE HONORABLE COURT OF APPEALS AND THE JUSTICES THEREOF:

COMES NOW APPELLANT, BRANDEE MICHELLE NICHOL, the Appellant, and moves the Court for an Second Extension of Time to File the Appellant’s Brief in this cause and in support thereof would show the Court as follows:

I.

Appellant’s Brief was due to be filed on Friday, January 2, 2015. Counsel filed a Motion for Extension of Time and said motion was granted. An Ordered was entered extending to February 4, 2015.

II.

Appellant, respectfully request that pursuant to T.R.A.P. 10.5(d) 38.6 (d)

that the Court grant an Extension of Time to file Appellant’s Brief until the 4th day of April, 2015, and in support thereof would respectfully show the Court that during the previous thirty Page 3

(30) days Counsel has been involved in the following:

1. Appellant’s Counsel has also been involved in capital murder pre-trials in the case styled the State of Texas v. Calvert in Smith County, Texas .

2. Undersigned Counsel has been involved with numerous federal cases and state misdemeanor and felony cases.

3. Undersigned Counsel respectfully requests this Honorable Court to extend the time for filing the Appellant’s Brief until the 4th day of April, 2015, in order to afford the undersigned Counsel the necessary time to conclude reading Appellant’s Record, researching the applicable law and preparing the Appellant’s Brief.

WHEREFORE PREMISES CONSIDERED, the undersigned Counsel, respectfully prays that his Honorable Court extend the time for filing Appellant’s Brief in this cause until the 4th day of April, 2015.

Respectfully submitted,

JEFF L. HAAS

Attorney at Law

908 First City Place

Tyler, Texas 75702

(903) 593-8338

Jeff Haas /s/

JEFF L. HAAS

STATE BAR NO. 08659600

ATTORNEY FOR APPELLANT

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing Motion for Extension of Time to File Appellant’s Brief has been delivered to the District Attorney's Office of Smith County, Texas, on this the 4TH day of February, 2015.

Jeff Haas /s/

JEFF L. HAAS

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