Cordero Brown v. State

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:

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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;

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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.”

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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

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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