Fred Douglas Moore, Jr. v. State

Opinion

ACCEPTED

06-15-00082-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

7/31/2015 11:21:50 AM

DEBBIE AUTREY

CLERK

NO. 6-15-00082-CR

FILED IN

6th COURT OF APPEALS

STATE OF TEXAS § IN THE COURT TEXARKANA, TEXAS 7/31/2015 11:21:50 AM

§

DEBBIE AUTREY

vs. § OF APPEALS Clerk

§

FRED DOUGLAS MOORE, JR. § SIXTH APPELATE DISTRICT

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Fred Douglas Moore, 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 196 District Courtt, Hunt County, Texas;

2. The case below was styled State of Texas vs. Fred Douglas Moore, Jr.

Cause Number 29,762.

3. Appellant was convicted of Robbery.

4. Appellant was sentenced to 12 years in the Texas Department of Corrections, Institutional Division.

5. Appellant's brief is currently due on July 27, 2015 6. Appellant requests an extension of time until July 31, 2015 7. No extension has previously been requested in this case.

8. Appellant is currently incarcerated.

9. 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, Appellant was on vacation and out of the office for 10 days.

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 Edward

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 July 31, 2015, a true and correct copy of the above and foregoing document was served on the Hunt County District Attorney's Office, service through the efiletexas website.

/s/Jessica Edwards

Jessica Edwards