James Jackson III v. State

Opinion

ACCEPTED 01-15-00330-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 9/16/2015 9:49:32 AM CHRISTOPHER PRINE CLERK

No. 01-15-00330-CR __________________________________________________________________ FILED IN 1st COURT OF APPEALS IN THE FIRST COURT OF APPEALS, TEXAS HOUSTON, TEXAS AT HOUSTON 9/16/2015 9:49:32 AM ______________________________________________ CHRISTOPHER A. PRINE Clerk JAMES JACKSON, Defendant-Appellant,

v.

THE STATE OF TEXAS, Plaintiff-Appellee. ______________________________________________

On Appeal from the 248th Judicial District Court Trial Court Case No. 1359103 ______________________________________________

APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE INITIAL BRIEF ________________________________________________

Robert L. Sirianni, Jr., Esq. Texas Bar No. 24086378 The Law Firm of Robert L. Sirianni, Jr. 201 N. New York Ave. Suite 200 P.O. Box 2047 Winter Park, Florida 32790 Tele: 407.388.1900 Fax: 407.622.1511 Robert@brownstonelaw.com Counsel for Defendant-Appellant

__________________________________________________________________ September 16, 2015 TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW, DEFENDANT-APPELLANT JAMES JACKSON,

through undersigned counsel in the above-styled cause, and respectfully submits this

Motion for Extension of Time to File Initial Brief, and as grounds would show unto

the Court the following:

1. Defendant-Appellant James Jackson recently retained the firm

Brownstone, P.A. and Robert L. Sirianni, Jr. to represent him on appeal.

2. The Initial Brief was due on August 27, 2015.

3. Undersigned counsel has not yet received the reporter’s and clerk’s

records, therefore, additional time will be necessary for Attorney Sirianni to

review said record, conduct the required research, and prepare the Initial Brief.

4. Accordingly, in the abundance of caution, Defendant-Appellant James

Jackson respectfully requests that this Court grant a 45-day extension of time,

up to and including October 11, 2015, to file the Initial Brief in this cause.

5. This extension of time is not requested for the purpose of delay, but so

that the issues on appeal are presented in the clearest and most effective

manner so that justice may be done in this cause. This is undersigned’s first

request for an extension of time.

WHEREFORE, Premises Considered, Defendant-Appellant respectfully

requests the entry of an order granting a 45-day extension of time, up to and 1 including October 11, 2015, to file the Initial Brief and to provide such further and

other relief that the Court may deem just, fair and equitable.

Respectfully Submitted,

/s/ Robert L. Sirianni, Jr. Robert L. Sirianni, Jr. Texas Bar No. 24086378 BROWNSTONE, P.A. 201 N. New York Ave. Suite 200 P.O. Box 2047 Winter Park, Florida 32790 Tele: 407.388.1900 Fax: 407.622.1511 Robert@brownstonelaw.com Counsel for Defendant-Appellant

CERTIFICATE OF SERVICE

Undersigned hereby certifies that on this 16th day of September, 2015, the

foregoing document has been filed electronically which will serve all counsel of

record.

/s/ Robert L. Sirianni, Jr. Robert L. Sirianni, Jr., Esq.

CERTIFICATE OF COMPLIANCE

Undersigned counsel certifies that the body of this document contains 238

words according to Microsoft Word.