Derrick Demond Cooks v. State

Opinion

ACCEPTED

12-15-00059-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

6/11/2015 9:44:36 PM

CATHY LUSK

CLERK

No. 12-15-00059-CR

DERRICK COOKS § IN THE COURT OF APPEALS FILED IN

Appellant § 12th COURT OF APPEALS TYLER, TEXAS

§

vs. § 12TH JUDICIAL 6/11/2015 DISTRICT 9:44:36 PM

CATHY S. LUSK

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

APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF -- FOUR DAY REQUEST

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 was due on 4 June 2015. A motion for extension of time was timely filed but has not yet been ruled on by the Court.

II.

While working on this case counsel has also been working on approximately 50 open appellate cases in this and other courts to which he has been appointed by Smith County. This has included investigating motions for new trials (looking for and talking with potential witnesses, jail and office visits with new appellate appointments, trial court appearances for the same), requests for and reviews of reporter’s and clerk’s records, research, briefing, review of opinions, investigation of potential PDR issues, etc. While not all of these seventy or so cases have required significant attention from counsel during this time, many of them have which ahs resulted form counsel having been able to devote the full attention necessary to this case prior to today’s date.

Because of this, counsel is requesting an additional four days to work on this brief.

II.

One prior extension, on which the Court has not yet ruled, has been requested and it is respectfully prayed that the in the interest of justice, the Court grant an extension of four days in this matter.

WHEREFORE, PREMISES CONSIDERED, undersigned counsel respectfully prays that, in accordance with the applicable law, the Court grant this Motion.

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