Cordero Brown v. State

• Court: Court of Appeals of Texas
• Decided: January 29, 2015
• Docket: 06-14-00115-CR
• Status: Published

Opinion

ACCEPTED 06-14-00115-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 1/29/2015 10:52:54 AM DEBBIE AUTREY CLERK

NO. 06-14-00115-CR

IN THE COURT OF APPEALS FILED IN FOR THE SIXTH APPELLATE DISTRICT6thTEXARKANA, COURT OF APPEALS TEXAS AT TEXARKANA 1/29/2015 10:52:54 AM DEBBIE AUTREY Clerk

CORDERO BROWN

VS.

THE STATE OF TEXAS

APPEALED FROM THE 124TH DISTRICT COURT, GREGG COUNTY TRIAL CAUSE NO. 42,258-B

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW CORDERO BROWN, Appellant, and respectfully

submits this, his First Motion for Extension of Time to file his Brief herein, and

pursuant to Rule 10.5(b), TEX.R.APP.P., and pursuant to the extension policies of

this Court, makes this request to extend time for filing the brief in this cause and

would show as follows:

I

The Official Court Reporter has filed the Reporter's Record with this

Honorable Court. The undersigned counsel has received the copies of the Reporter’s

Record and Clerk’s Record. The deadline for filing Appellant’s brief is due on or

before February 2, 2015.

II.

Appellant requests an additional thirty (30) days in which to complete the

research and writing necessary for submission of the brief.

III.

As reasonable explanation for the need for an extension Appellant would show

as follows:

1. While Counsel for Appellant has devoted time to reading the

record, research, and drafting the Brief, the Brief is not yet finished.

2. Appellate counsel has also, during the past 30 days, devoted his time

to other matters in his office, including, but not limited to, representation in

the following matters:

A. Criminal Appeals

State v. Karl Houlditch, Cause No. 13,0263X, 71st District Court of Harrison

County: preparing for and presenting Motion for New Trial on January 25, 2015;

plus additional memorandum of law to trial court

Tommy Scott Thomas, Cause No. PD-0057-15, drafting and filing Petition

for Discretionary review in Court of Criminal Appeals of Texas

Esaw Lampkin, Cause No. 06-14-00024-CR; correspondence with client

Kadeem Ray, Cause No. 06-14-00106-CR; correspondence with client

Cinque Ross, Cause No.s 06-14-00157-CR and 06-14-00206-CR;

correspondence with client

B. Probate & Estate Work

Estate of Harriet Hall, initial conferences on probate of will; drafting

application and other documents, with intent to file week of February 2, 2015.

C. Child Protective Services Work

CPS conferences, court hearings, correspondence in the following cases:

No. 2014-873-DR, “Interest of J.V. & K.V.”

No. 2013-955-DR, “Interest of A.T.”

No. 2014-180-DR, “Interest of K.M. & K.J.”

No. 2014-2343-DR, “Interest of J.L.B.”

No. 2014-1891-DR, “Interest of G.L.H.”

No. 2014-1596-DR, “Interest of J. S., S. H., AND R. H.”

Correspondence in appeal No. 06-14-00087-CV, “In the Interest of

J. M. A. E. W., A Child” pending in this case; reading State’s brief and Guardian Ad

Litem’s brief

D. Civil Litigation

Drafting discovery, motions, getting settings and/or other activities in following:

Cause No. 2014-2434-CCL2, Pope & Turner, Inc. of Overton, vs. John Edward

McDade, Jr., et al, pending in County Court at Law No. 2, Gregg County

Cause No. CV14-1856, Sacor Financial, Inc., etc. vs. Texas Bank & Trust, pending

in 43rd District Court of Parker County, action in garnishment

Counsel has also spent several hours in conference during each week of the

past 30- day period with clients who have consulted with counsel on such diverse

areas of law as collections, criminal law, probate, juvenile, and other legal matters.

With a grant of an additional thirty days Appellate counsel plans to finish

writing the brief and submit it to the Court.

IV.

There has previously been no motion filed for extension of time, or grants of

time extended to Appellant, for the filing of Appellant's brief.

WHEREFORE, PREMISES CONSIDERED, CORDERO BROWN,

Appellant, respectfully requests that this Honorable Court of Appeals will, upon

reviewing this Motion, grant the extension of time for filing Appellant's brief as

requested herein, and for such other relief to which Appellant may be entitled.

Respectfully submitted,

LAW OFFICES OF LEW DUNN

_/s/ Lew Dunn_ Lew Dunn Attorney at Law 201 E. Methvin, Suite 102 P.O. Box 2226 Longview, Texas 75606 903-757-6711 FAX 903-757-6712 Texas State Bar No. 06244600 ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

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

was hand-delivered or sent by first class mail or by electronic transmission to

the office of Hon. Zan Colson Brown, Assistant Criminal District Attorney,

Gregg County Courthouse, 101 E. Methvin, Longview, Texas 75601 on this 29

day of January, 2015.

/s/_LewDunn_____________ Lew Dunn COUNSEL FOR APPELLANT