Joey Huddleston v. State

Opinion

ACCEPTED

06-16-00023-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS 7/1/2016 2:41:15 PM

DEBBIE AUTREY

CLERK

No. 06-16-00023-CR

IN The Sixth Court of Appeals FILED IN 6th COURT OF APPEALS

TEXARKANA, TEXAS

Texarkana, Texas 7/1/2016 2:41:15 PM DEBBIE AUTREY

Clerk

JOEY HUDDLESTON,

Appellant,

V.

THE STATE OF TEXAS,

Appellee.

Appellant’s Unopposed First Motion for Extension of

Time to File Appellant’s Brief

TO THE HONORABLE SIXTH COURT OF APPEALS:

Pursuant to TEX. R. APP. P. 10.5(b) and 38.6(d), the

Appellant, Joey Huddleston, files this Unopposed First

Motion to Extend Time to File Appellant’s Brief.

Appellant’s opening brief was originally due on July

6, 2016. Counsel for Appellant requests a 30-day

extension of time to file its brief, making the brief due

on August 5th, 2016.

Counsel for Appellant relies on the following

reasons, in addition to the routine matters that counsel

must attend to in daily practice, to explain the need for

the requested extension:

Counsel has an unusually high number of cases set on a felony trial/status docket in the 188th District Court of Gregg County on July 6th, 2016, which is the current due date for Appellant’s Brief. The cause numbers set on that docket are as follows: 45,060-A; 45,316-A; 45,364-A; 45,426-A; 45,536-A; 45,592-A; 45,613-A; 45,722- A; 47,734-A; and 45752-A. Counsel has had to spend a considerable amount of time visiting with these Defendants and preparing for their upcoming trials and pretrial matters. Counsel also was recently appointed to represent an individual accused of murder (among the usual court appointments), and Counsel has had to expend an unexpectedly large amount of time dealing with that case. Also, Counsel had hoped to spend some personal time with his family over the July 4th holiday weekend. Counsel for Appellant seeks this extension of time

to be able to prepare a cogent and succinct brief to aid

this Court in its analysis of the issues presented. This

request is not sought for delay but so that justice may

be done.

The undersigned has conferred with opposing counsel, and

opposing counsel has indicated that his client does not oppose

this motion.

All facts recited in this motion are within the

personal knowledge of the counsel signing this motion,

therefore no verification is necessary under Rule of

Appellate Procedure 10.2.

PRAYER FOR RELIEF

For the reasons set forth above, Appellant requests

that this Court grant this Unopposed First Motion to

Extend Time to File Appellant’s Brief and extend the

Deadline for Filing the Appellant’s Brief up to and

including August 5th, 2016. Appellant requests all

other relief to which it may be entitled.

Respectfully submitted, /s/Jeff T. Jackson__ Jeff T. Jackson SBOT No. 24069976 736-A Hwy 259 N. Kilgore, TX 75662 Phone: 903-654-3362 Fax: 817-887-4333 Attorney for Appellant,

Joey Huddleston

CERTIFICATE OF SERVICE

Pursuant to Tex. R. App. P. 9.5, I certify that on

July 1, 2016, a copy of this motion was served on

Appellee’s counsel by e-File systems and email.

/s/Jeff T. Jackson__ Jeff T. Jackson