DeAndre Dwight Joseph A/K/A Joseph DeAndre A/K/A DeAndre Dwight Parks A/K/A/ DeAndre Parks A/K/A DeAndre Joseph A/K/A DeAndra Dwight Joseph v. State

Opinion

ACCEPTED

03-15-00209-CR

5583657

THIRD COURT OF APPEALS

June 8, 2015 AUSTIN, TEXAS 6/8/2015 1:43:08 PM

JEFFREY D. KYLE

CLERK

IN THE

THIRD COURT OF APPEALS

OF TEXAS

DEANDRE DWIGHT JOSEPH § §

V. § CAUSE NUMBER 03-15-00209-CR §

THE STATE OF TEXAS §

APPELLANT’S MOTION TO EXTEND THE TIME TO FILE THE APPELLATE BRIEF

TO THE HONORABLE THIRD COURT OF APPEALS:

Deandre Dwight Joseph files Appellant’s Motion To Extend The Time To File The Appellate Brief and would show as follows:

I.

Appellant was convicted of aggravated assault and attempted arson in State of Texas v. Deandre Dwight Joseph, Cause Number D-1-DC-15-904009 in the 403rd District Court of Travis County. The jury assessed his punishment at 54 years in prison for aggravated assault and 25 years for attempted arson on March 11, 2015. Appellant gave timely notice of appeal.

II.

The appellate brief is due on June 15, 2015. Appellant requests an extension of time until July 31, 2015, to file the brief.

III.

The court has not previously granted an extension of time.

IV.

For good cause, appellant would show that appellate counsel, Randy Schaffer, will not have sufficient time to prepare the brief by June 15 because he was hired on June 3 and has requested, but does not yet have, the appellate record. Counsel has a suppression hearing on June 26 in State v. Ballard, No. 14-07- 07804, in the 359th District Court of Montgomery County and must file a brief in Bezerra v. State, No. 07-15-00018-CR, in the Seventh Court of Appeals by June 26. Counsel will not be able to commence preparation of appellant’s brief before June 27.

Appellant moves that the court extend the time to file the appellate brief to July 31, 2015.

3

Respectfully submitted,

/s/ Randy Schaffer

State Bar No. 17724500

1301 McKinney, Suite 3100 Houston, Texas 77010

(713) 951-9555

(713) 951-9854 (facsimile)

noguilt@swbell.net

Attorney for Appellant

DEANDRE DWIGHT JOSEPH

CERTIFICATE OF SERVICE

I served a copy of this document on Rosemary Lehmberg, District Attorney, Travis County Courthouse, P.O. Box 1748, Austin, Texas 78767, by United States mail, postage prepaid, on June 8, 2015.

/s/ Randy Schaffer