Jason Burrows v. State

Opinion

ACCEPTED

01-15-00302-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS 9/9/2015 6:57:52 PM CHRISTOPHER PRINE

CLERK

NO. 01-15-00302-CR

FILED IN

1st COURT OF APPEALS

IN THE COURT OF APPEALS HOUSTON, TEXAS 9/9/2015 6:57:52 PM

FOR THE CHRISTOPHER A. PRINE Clerk

FIRST SUPREME JUDICIAL DISTRICT OF TEXAS

AT HOUSTON

JASON BURROWS § Appellant §

V. § §

THE STATE OF TEXAS § Appellee

APPELLANT'S REQUEST FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE COURT OF APPEALS:

Counsel for Appellant requests an Extension of Time to File the Appellant's Brief; the following is satisfied:

1. The District Court of Brazoria County rendered judgment on March 27, 2015;

2. Appellant's trial court number is 74447;

3. The appeal in this case was perfected on March 27, 2015;

4. The Transcript and Statement of Facts were filed on August 10 , 2015 and consists of nine (9) volumes of exhibits and testimony;

5. Notice of said filing was received by Appellate Counsel sometime after the postmarked date of August 12, 2015, however dure to family vacation, such was not received until August 21, 2015.

6. Counsel received a copy of said Transcript and Statement of Facts on September 4, 2015.

7. Appellant's Brief is due on September 9, 2015;

8. No previous Motions for Extension of Time to File Brief have been filed;

9. Appellant requests sixty days to complete said brief;

10. The facts relied upon to support this request for an extension are:

Appellant's brief is well on its way to being completed. However, due to

being involved in the following trials, I have been unable to file the brief within the

original deadline:

a. State of Texas v. David Amerson Cause No. CR-15-0138 Hays County District Court Trial Scheduled– August 24, 2015;

b. State of Texas v. Alex Garcia Cause No. 2014CR0730 Coaml County Court at Law No. 2 Trial Scheduled – September 8, 2015;

Therefore, appellant prays that this Court grant an extension of time of sixty

(60) days so that Appellant can properly review the record and file a brief.

Respectfully submitted,

Scot Courtney Attorney for Appellant P. O. Box 787 San Marcos, Texas 78667-0787 512-392-9292 512-532-6766 FAX EM-sanmarcoslaw@gmail.com State Bar #00790515

CERTIFICATE OF SERVICE

By affixing his signature to the foregoing instrument, Scot Courtney certifies that a true and correct copy of the same has been had delivered to the office of the Brazoria County District Attorney's Office, on this the 9th day of September, 2015.

Scot R. Courtney

CERTIFICATE OF CONFERENCE By affixing his signature to the foregoing instrument, Scot Courtney certifies that Counsel has confferred with Appelare Counsel and Appellate Counsel, listed below and Appellant’s Counsel does not oppose the Motion.

Scot Courtney

Brazoria County District Attorney David Bosserman 111 E. Locust St. Angleton, TX 77515