Gary Christopher Morrow v. State

Opinion

ACCEPTED 06-15-00012-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 8/31/2015 3:03:32 PM DEBBIE AUTREY CLERK No. 06-15-00012-CR, 06-15-00013-CR, 06-15-00014-CR, 06-15-00015-CR, 06-15-00016-CR, 06-15-00017- CR

In the Court of Appeals for the FILED IN Sixth District of Texas 6th COURT OF APPEALS At Texarkana TEXARKANA, TEXAS 8/31/2015 3:03:32 PM DEBBIE AUTREY Clerk GARY MORROW, Appellant

v.

STATE OF TEXAS, Appellee

SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT GARY MORROW

COMES NOW, Micah Belden, Counsel for Gary Morrow, and moves for a thirty day

extension of time and would show:

The Court Reporter's record was filed on June 29, 2015. Counsel has been unable to file

his Appellant's brief herein by the extended deadline of August 28, 2015, due to the very large

volume of the reporter's record which is in approximately ten volumes and over two thousand

pages. Additionally, the reporter's record will have to be supplemented with the motion for new

trial hearing, as it has one of the key appeal points placed on the record regarding punishment

evidence. Counsel prays that the deadline be extended until September 27, 2015, at which time

Counsel represents that he should be able to file the appellant's brief in all reasonable likelihood.

Counsel has had two jury trial settings in the last five weeks, both of which went to trial although

one pled after voir dire, and is a solo practitioner working diligently on the brief. However, it is

an unusually long record (believed to be the longest this attorney has dealt with in a non-capital case), and the case involves complex issues including ownership for burglary purposes between

two spouses and whether an expert should have been hired for punishment.

Respectfully submitted,

Is! Micah Belden Micah Belden 711 N. Travis Sherman, TX 75090 Telephone: (903) 744-4252 Fax: (903) 893-1734 State Bar No. 24044294 Board Certified in Criminal Law Texas Board of Legal Specialization

CERTIFICATE OF SERVICE

I do hereby certify that on this August 28, 2015, a true and correct copy of this motion was forwarded by email to:

Brad Setterberg Assistant Fannin County District Attorney 101 E. Sam Rayburn, Third Floor Bonham, TX 75418

VERIFICATION BEFORE ME, the undersigned authority, on this day personally appeared 1 t 84de" , who after being duly sworn stated:

"My name is ,/P 1Af (-PO . I am the petitioner in the above entitled and numbered 7feet cause. I have read the attached Petition for Occupational Driver's License and hereby state that said Petition is true and correct to the best of my knp ledge."

SUBSCRIBED AND SWORN TO BEFORE ME on , 2015, to certify which witness my hand and seal of office.

B JERRY McGOWEN III NOTARY PUBLIC STATE OF TEXAS My Comm. Exp. 02/14/2010 Notary Pub)lic,‘State of Texas