Dorsey Nathaniel Carr III v. State

Opinion

ACCEPTED 01-15-00246-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 7/21/2015 1:40:02 PM CHRISTOPHER PRINE CLERK

Cause No. 01-15-00246-CR

FILED IN DORSEY NATHANIEL CARR, III * IN THE COURT 1st OF COURT APPEALSOF APPEALS APPELLANT * HOUSTON, TEXAS * 7/21/2015 1:40:02 PM V. * FIRST DISTRICT CHRISTOPHER A. PRINE Clerk *

THE STATE OF TEXAS, * APPELLEE * HOUSTON, TEXAS

MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF

Comes now DORSEY NATHANIEL CARR, III, through his

attorney of record John J. Davis, and files this Motion For

An Extension of Time in which to file Appellant's Brief

pursuant to Rules 10.5(b) and 38.6(d) of the Texas Rules of

Appellate Procedure. In support of this Motion, Appellant shows the Court the following:

I.

TRIAL COURT: 239th District Court of Brazoria County, Texas, Judge Patrick Sebesta, presiding. CAUSE NUMBER: 74,219

STYLE: The State of Texas vs. Dorsey Nathaniel Carr, III

DATE OF JUDGMENT: February 20, 2 015

CONVICTION (OFFENSE): Felony DWI Enhanced

SENTENCE: Ten (10) years TDCJ-ID.

DEADLINE FOR FILING APPELLANT'S BRIEF: July 22, 2015

LENGTH OF TIME REQUESTED FOR EXTENSION: August 21, 2015 (30 days)

NUMBER OF PREVIOUS EXTENSIONS GRANTED: None II. REASONS FOR EXTENSION

Appellant's request for an extension is based upon the following facts:

Counsel is the defense counsel for the Brazoria County Drug Court which meets every week and requires additional time for client conferences. Counsel is also the appointed defense counsel at probation reviews in the 149th and 239th

District Courts as well as the appointed defense counsel for the jail dockets in County Court at Law Number 1 of Brazoria

County. Counsel's case load and the settings and requirements of the drug court and the review and jail dockets coupled with the need of a sole practitioner to meet with clients and

maintain some semblance of a cash flow have resulted in Counsel being unable to finish the brief by the stated deadline.

WHEREFORE, PREMISES CONSIDERED, Appellant prays the Court grant this MOTION FOR EXTENSION OF TIME TO FILE

APPELLANT'S BRIEF and extend the time for filing the Brief until August 21, 2015.

Respectfully submitted,

/s/ John J. Davis

John J. Davis P.O. Box 787 2 05 N. Chenango Angleton, Texas 77516-0787 SBN 05515500 Telephone: (979) 849-4362 d.attorne@sbcglobal.net

ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF was served to:

Jeri Yenne Criminal District Attorney Brazoria County Courthouse 111 East Locust, Suite 408A Angleton, Texas 77515 ATTENTION: David Bosserman VIA FACSIMILE (979) 864-1525

on the 21st day of July, 2015

John J. Davis Attorney for Appellant