Carlton Merle Daniel Jones v. State

Opinion

ACCEPTED 06-15-00119-cr SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/14/2015 12:20:45 PM DEBBIE AUTREY CLERK

NO. 06-15-00119-CR IN THE FILED IN 6th COURT OF APPEALS SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/14/2015 12:20:45 PM OF TEXAS DEBBIE AUTREY TEXARKANA, TEXAS Clerk

Carlton Daniel Jones, APPELLANT

THE STATE OF TEXAS, APPELLEE

On appeal from the 196'" Judicial District Court Of Hunt County, Texas

Trial Court Cause No. 30,042

APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF CARLTON DANIEL JONES IN THK COURT OF APPEALS

6TH SUPREME JUDICIAL DISTRICT

STATE OF TEXAS TEXARKANA, TEXAS

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

NO%' COMES CARLTON DANIEL JONES, the Appellant in the above styled and

numbered cause, and would respectfully request an extension of time for filing the Appellee's

brief in said case pursuant to Rule 10.5 and Rule 38 of the Texas Rules of Appellate Procedure,

and would respectfully show the following:

Appellee's brief is due to be filed on or before the 14th day of December 2015,

Appellee respectfully requests this Honorable Court to grant an extension of time to file

the Appellant's Brief for additional thirty (30) days time from this date to complete and file his

Opening, or until the 14'" day of January 2016. In connection therewith, Appellant would show

the following facts relied upon in good faith to show good cause to the Honorable Court of

Appeals regarding this motion for extension of time:

Counsel for Appellant became aware of the record in this case and has made diligent

efforts to review the record and prepare a thorough Opening Brief. Appellant anticipates that

one of the issues for review will concern the sufficiency of the evidence. The record includes

exhibits containing recordings taken from the Hunt County jail and the review of these

conversations has required some effort to obtain recorded copies of the DVD exhibits that are

audible. Appellant has now completed a review of the record and expects to complete the Opening Brief within a few days of the original due date. Counsel for Appellee does not oppose

this Motion.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests and prays

that the Honorable Court of Appeals grant an extension of thirty (30) days or until January14,

2015 in which the Appellant may complete and file his brief,

Respectfully submitted,

Peter I. Morgan Counsel For Appellant State Bar No 14451700 P.O. Box 984 Greenville, Texas 75403 pmorgan@lawyermorgan. corn (903) 217-3671 (903) 642-0057 (fax)

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing instrument was

forwarded to all parties by hand delivery or regular mail.

Peter I, Morgan VERIFICATION

STATE OF TEXAS

COUNTY OF HUNT

BEFORE ME, the undersigned Notary Public, on this day personally appeared

PETER I. MORGAN, who being by me duly sworn on his oath deposed and said that he is duly qualified and authorized in all respects to make this affidavit; that he has read the

above and foregoing Motion for Extension of Time for Filing Brief; and that every

statement contained in the Motion is within 's nowledge and true and correct.

eter I. Morgan

SUBSCRIBED AND SWORN TO BEFORE ME on the day of December 2015, to certify which witness my hand and official seal.

+,w.".'c'~, REBECCA BLEVlNS Notary Public, State of Texas 'p~ Notary Public, State of Texas . :.~:;»! ~. My Commlssiorr Expires