Cornelius Milan Harper v. State

Opinion

ACCEPTED 01-14-00641-cr

FIRST COURT OF APPEALS

HOUSTON, TEXAS 5/7/2015 3:14:05 PM CHRISTOPHER PRINE

CLERK

No. 01-14-00641-CR

In the FILED IN 1st COURT OF APPEALS

COURT OF APPEALS HOUSTON, TEXAS For the 5/7/2015 3:14:05 PM FIRST SUPREME JUDICIAL DISTRICTCHRISTOPHER A. PRINE at Houston Clerk

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On Appeal from the 434th District Court of Fort Bend County, Texas Cause Number 11-DCR-056513

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CORNELIUS MILAN HARPER, Appellant v.

THE STATE OF TEXAS, Appellee

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APPELLANT’S MOTION FOR EXTENSION OF TIME

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TO THE HONORABLE JUSTICES OF THE FIRST COURT OF

APPEALS:

COMES NOW, Cornelius Milan Harper, Appellant herein, by and through

his attorney of record, Kristen Jernigan, and files this, his Motion for Extension of

Time. In support of said motion, Appellant would show the Court the following:

1. Appellant’s brief was due in this case on April 22, 2015.

2. Appellant seeks an extension of sixty day in which to file his brief, making his brief due on or before June 21, 2015.

3. The undersigned inadvertently calendared the due date for Appellant’s brief as May 22, 2015, instead of April 22, 2015. Nonetheless, the undersigned requested, and has received from this Court a copy of the Clerk’s Record and Reporter’s Record on disk and has begun review of those records. The Clerk’s

Record is 1,034 pages and the Reporter’s Record consists of seventy-one volumes.

4. The undersigned, in the past thirty days, has filed briefs in the Third Court of Appeals in the cases of Christopher Brian Roberts v. The State of Texas, No. 03-14-00637-CR; Timothy Colt Castleberry v. The State of Texas, No. 03-14-00599-CR; and has completed the brief in Rex Allen Nisbett v. The State of Texas, No. 03-14-00402-CR, which will be filed May 8, 2015. Additionally, the undersigned filed a brief in the Fourteenth Court of Appeals in the case of Joseph Henry Edward Haynes v. The State of Texas, No. 14-15-00040-CR. The undersigned also filed Petitions for Writ of Habeas Corpus in the cases of Ex parte Robert Jesse Padilla, Jr., No. 06-921-K368 & No. 06-937-K368, in the 368th District Court of Williamson County, Texas. Finally, the undersigned has made numerous Court appearances and has undertaken the tasks associated with the practice of a solo attorney’s office.

5. The undersigned has not filed any previous motions for extension of time in this case.

6. For the reasons set forth above, Appellant respectfully requests that he be granted an extension of sixty days so that his brief in this case will now be due on June 22, 2015.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully

requests that this Court grant his Motion for Extension of Time.

Respectfully submitted,

_______/s/__Kristen Jernigan______ KRISTEN JERNIGAN State Bar Number 90001898 207 S. Austin Ave. Georgetown, Texas 78626 (512) 904-0123 (512) 931-3650 (fax) Kristen@txcrimapp.com

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the

foregoing Appellant’s Motion for Extension of Time has been mailed to the Fort

Bend County District Attorney’s Office, 301 Jackson Street, Richmond, Texas

77469, on May 7, 2015.

__/s/ Kristen Jernigan__________________ Kristen Jernigan