Dennis Lynch v. State

Opinion

ACCEPTED

12-14-00328-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

6/22/2015 3:41:35 PM

CATHY LUSK

CLERK

No. 12-14-00328-CR

DENNIS LYNCH § IN THE COURT OF APPEALS FILED IN

Appellant § 12th COURT OF APPEALS TYLER, TEXAS

§

vs. § 12TH JUDICIAL 6/22/2015 DISTRICT 3:41:35 PM

CATHY S. LUSK

§ Clerk THE STATE OF TEXAS, § Appellee § AT TYLER, TEXAS

APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF PENDING COURT’S DISMISSAL OF APPEAL

TO THE HONORABLE COURT:

Now comes Austin Reeve Jackson, counsel for Appellant in the above entitled and numbered cause, and makes this Motion, and for good cause shows the following:

I.

Appellant’s brief in this matter is due on 25 June 2015. No prior extensions have been requested.

II.

Counsel has filed a memorandum with the Court outlining that Mr. Lynch waived his right to appeal at the time he entered his plea in this case. Additionally, the trial court has filed findings of fact with the Court indicating the same thing. Therefore, Counsel believes the Court must dismiss this appeal. Therefore, pending the Court’s decision on that issue, Counsel would request the Court extend the time to file brief in this matter.

II.

No prior extensions have been requested and is respectfully prayed that the in the interest of justice, the Court grant this motion.

WHEREFORE, PREMISES CONSIDERED, undersigned counsel respectfully prays that, in accordance with the applicable law, the Court grant this Motion and extend the date by which to file a brief by thirty days.

Respectfully submitted,

/s/Austin Reeve Jackson

Texas Bar No. 24046139

112 East Line, Suite 310

Tyler, TX 75702

Telephone: (903) 595-6070 Facsimile: (866) 387-0152

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing document was served on counsel for the State by facsimile concurrently with its filing.

/s/Austin Reeve Jackson