Edwrick Quentria Bass v. State

Opinion

ACCEPTED 03-15-00628-CR 8215845 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/14/2015 10:11:13 AM JEFFREY D. KYLE CLERK NO. 03-15-00628-CR

IN THE COURT OF APPEALS FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS THIRD DISTRICT OF TEXAS AT AUSTIN 12/14/2015 10:11:13 AM JEFFREY D. KYLE Clerk *******************************************************

CAUSE NO. 74,201

IN THE 426TH JUDICIAL DISTRICT COURT OF

BELL COUNTY, TEXAS

******************************************************* EDWRICK QUENTRIA BASS APPELLANT

VS.

THE STATE OF TEXAS APPELLEE *******************************************************

APPELLANT’S MOTION FOR EXTENSION

OF TIME TO FILE BRIEF

COMES NOW Appellant, EDWRICK QUENTRIA BASS, by and

through his attorney of record, James H. Kreimeyer, and

respectfully moves the Court to extend the time for filing

the Appellant’s Brief in this cause, and in support hereof

would show the Court as follows:

I.

On August 4, 2015, Appellant entered a plea of not guilty, to the offense of assault on a family

member/dating relationship with prior misdemeanor

convictions for assault causing bodily injury against a

family member; and a jury found him guilty. The

punishment assessed by the court was eleven years in the

Texas Department of Criminal Justice, Institutional

Division imposed on September 15, 2015. A notice of

appeal was filed by appellant on October 7, 2015.

II.

Appellant’s Brief is due for filing with the Court

of Appeals on December 14, 2015.

III.

Appellant’s attorney would respectfully request an

extension of time to file Appellant’s brief. Counsel for

appellant has just completed the appellate brief in Karl

Lee Wiggins v. State, No. 03-15-00385-CR. The appellate

record in this appellant’s appeal is nine (9) volumes.

Counsel needs additional time to read the record and

prepare the appellate brief.

This Motion for Extension of Time is not filed for the purpose of delay, but so that the ends of justice may

be served.

WHEREFORE, PREMISES CONSIDERED, Appellant requests

the Court to grant a forty five (45) day extension of time

to file the brief herein until January 28, 2016.

Respectfully submitted,

/s/ James H. Kreimeyer JAMES H. KREIMEYER ATTORNEY FOR APPELLANT P.O. BOX 727 BELTON, TEXAS 76513 (254) 939-9393 (254) 939-2870 FAX T.S.B. #11722000 jkreime@vvm.com

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of

the foregoing Appellant’s Motion for Extension of Time

to File Brief was delivered to Henry Garza, District

Attorney, Bell County Courthouse, Belton, Texas 76513,

on the 14th day of December 2015.

/s/ James H. Kreimeyer JAMES H. KREIMEYER ATTORNEY FOR APPELLANT