Evender Gene Jackson v. State

• Court: Court of Criminal Appeals of Texas
• Decided: November 17, 2015
• Docket: 06-15-00151-CR
• Status: Published

Opinion

ACCEPTED 06-15-00151-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 11/17/2015 11:22:13 AM DEBBIE AUTREY CLERK

NO. 6-15-00151CR FILED IN 6th COURT OF APPEALS STATE OF TEXAS § IN THE COURT TEXARKANA, TEXAS 11/17/2015 11:22:13 AM § DEBBIE AUTREY vs. § OF APPEALS Clerk

§ EVENDER GENE JACKSON, JR. § SIXTH APPELATE DISTRICT

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Evender Gene Jackson, Jr., Appellant in the above styled and numbered

cause, and moves this Court to grant and extension of time to file Appellant's brief pursuant to

Rule 38.6 of the Texas Rules of Appellant Procedure and for good cause shows the following:

1. This case is on appeal from the 196th District Court, Hunt County, Texas;

2. The case below was styled State of Texas vs. Evender Gene Jackson, Jr.,

Cause Number 30,536.

3. Appellant was convicted of Aggravated Robbery with a Deadly Weapon.

4. Appellant was sentenced to 50 years in the Texas Department of Criminal

Justice, Institutional Division.

5. Notice of Appeal was given on August 14, 2015.

6. The Clerk's record was filed on October 13, 2015; The Reporter's record

was filed on October 12, 2015.

7. Appellant's brief is currently due on November 13, 2015.

8. Appellant requests an extension of time of 30 days from the current due

date. 9. No extension has previously been requested in this case.

10. Appellant relies on the following facts as good cause for the extension

requested:

Appellant's attorney, Jessica Edwards, has received the record but has had

insufficient time to adequately examine the record in order to effectively prepare a brief in this

case.

Counsel would also show this court that, since receiving the record in this case,

counsel was admitted to the hospital on October 26, 2015 and required an invasive surgical

procedure. Counsel is returning to work full time today, November 17, 2015. Counsel has had

insufficient time to review the record and prepare the brief.

WHEREFORE, PREMISIS CONSIDERED, Appellant prays that this Court

would grant Appellant's Motion to Extend Time to File Appellant's Brief, and for such other and

further relief as the Court may deem appropriate.

Respectfully submitted,

_/s/ Jessica Edwards_____________ Jessica Edwards SBN: 24000994 P.O. Box 9318 Greenville, Texas 75404 Tel: (903) 513-0510 Fax: (903) 200-1359 E-Mail: jessicaedwardslaw@gmail.com Attorney for Timothy Bates

CERTIFICATE OF SERVICE

This is to certify that on November 17, 2015, a true and correct copy of the above and

foregoing document was served on the Hunt County District Attorney's Office, by electronic delivery.

/s/ Jessica Edwards Jessica Edwards