Joseph Christopher Lewis v. State

Opinion

ACCEPTED 09-17-00060-CR NINTH COURT OF APPEALS BEAUMONT, TEXAS 12/13/2017 5:05 PM CAROL ANNE HARLEY CLERK

NO:09-17-00060-CR TRIAL COURT CASE NO(s) 12519 FILED IN COURT OF APPEALS 9th COURT OF APPEALS NINTH DISTRICT BEAUMONT, TEXAS BEAUMONT, TEXAS 12/13/2017 5:05:13 PM CAROL ANNE HARLEY JOSEPH LEWIS § APPEAL FROM Clerk THE 1-A DISTRICT § COURT § vs. § OF § THE STATE OF TEXAS, APPELLEE § TYLER COUNTY, TEXAS

MOTION TO EXTEND THE TIME FOR FILING APPELLANT’S BRIEF

TO THE HONORABLE COURT OF APPEALS:

COMES NOW the Appellant and moves the Court for an extension of time to file a

Appellant’s brief in the cause, and in support thereof would show the Court as follows:

I.

On January 9th , 2009, the Appellant plead Guilty, to the offense of Aggravated Sexual

Assault of a Child. On February 9th, 2017, he was found guilty by jury verdict, and was sentenced

on February 9th, 2017, to a Life sentence in the Texas Department of Criminal Justice, under Cause

No. 12,519; THE STATE OF TEXAS VS. JOSEPH CHRISTOPHER LEWIS; IN THE 1-a

DISTRICT COURT OF TYLER COUNTY, TEXAS. THE STATE OF TEXAS VS. JOSEPH

LEWIS; IN THE 1-A DISTRICT COURT OF TYLER, TEXAS.

II.

The Appellant timely filed his Notice of Appeal and the Transcript and Statement of Facts

were timely filed herein, and the Appellant’s Brief was due to be filed herein on December 13th,

2017. III.

Appellant respectfully requests that this Honorable Court grant an additional extension of approximately thirty (30) days or until January 12th, 2018, in filing Appellant’s Brief

IV.

The such extension is necessary for the following reasons:

1. Counsel makes this request for extension because he has been scheduled in multiple

counties on the felony trial dockets in Jefferson, Hardin, Liberty, Newton, and Tyler Counties, for

announcement, pretrial and trial dockets. Counsel has been heavily scheduled on the Hardin County

Dockets, in both the 356th and 88th Judicial District Courts. Counsel sincerely apologizes to this

honorable court for filing an additional extension and wishes to remain in good standing with this

Honorable Court, but he prays that the court will grant this second extension to allow the needed

time to finalize and file Appellant’s Brief to ensure accuracy and eliminate the possibility of error.

2. As well, counsel respectfully informs the court he has been working on several other

briefs, (in the Ninth Court of Appeals), writs and petitions for discretionary review, during this time

of which have required more than the usual amount of time in research and reviewing case law.

3. Counsel informs the court this extension is not sought for delay, but that justice may

be done.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests and prays

that this Honorable Court extend the time for the filing of Appellant’s Brief herein approximately

on January 12th, 2018. Respectfully submitted,

/s/ Bryan S. Laine Bryan S. Laine TBN. #24011488 1045 S. Redwood Kountze, Texas 77625 Tel: (409) 246-4008 Fax: (409) 246-3645 bryanlaine@gt.rr.com CERTIFICATE OF SERVICE

I hereby certify that true and correct copy of the foregoing document has been forwarded

to all opposing counsel and parties on this the 13th day of December 2017.

By:/s/ Bryan S.Laine /s/Bryan S. Laine State Bar No. 24011488 NO:09-17-00060-CR TRIAL COURT CASE NO(s) 12,519

COURT OF APPEALS NINTH DISTRICT BEAUMONT, TEXAS

JOSEPH LEWIS § APPEAL FROM THE 1-A DISTRICT § COURT § vs. § OF § THE STATE OF TEXAS, APPELLEE § HARDIN COUNTY, TEXAS

ORDER

On________________________, 2017, came on to be considered JOSEPH LEWIS’S

Appellant’S Motion to Extend the Time For Filing Appellant’s Brief and said motion is hereby:

(Granted) (Denied)

JUDGE PRESIDING