Joseph Emmanuel Watkins v. State

Opinion

ACCEPTED

06-16-00054-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

6/30/2016 11:49:06 AM

DEBBIE AUTREY

CLERK

NO. 06-16-00054-CR

STATE OF TEXAS § IN THE FILED IN

§ 6th COURT OF APPEALS VS. § 6TH COURT TEXARKANA, TEXAS § 6/30/2016 11:49:06 AM JOSEPH EMMANUEL WATKINS § OF APPEALS DEBBIE AUTREY Clerk

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes JOSEPH EMMANUEL WATKINS, Appellant in the above styled and numbered cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following:

1. This case is on appeal from the 13TH Judicial District Court of Navarro County, Texas.

2. The case below was styled the STATE OF TEXAS vs. JOSEPH EMMANUEL WATKINS, and numbered D34,763-CR.

3. Appellant was convicted of Theft Over $1500.

4. Appellant was assessed a sentence of 13 months TDC on 2/12/16.

5. Notice of appeal was given on 3/2/16.

6. The clerk's record was filed on 6/14/16; the reporter's record was filed on 6/14/16.

7. The appellate brief is due on 7/14/16.

8. Appellant requests an extension of time of 30 days from the due date, i.e. 8/14/16.

9. No previous extensions to file the brief has been received in this cause.

10. Defendant is currently incarcerated.

11. Appellant relies on the following facts as good cause for the requested extension:

Appellant’s Counsel is self-employed and a sole practitioner. Due to counsel’s case load and other work and personal obligations, counsel did not have adequate time to research and prepare the issues in this case within the 30 day period. Counsel was working on two other briefs being filed with the courts this week including Ipina v. State, 10-16-00052, and Crenshaw v. State, 06-16-00061. Counsel has one other brief due in this Court in Liberto v. State, 06-16-00063. Counsel will be out of the country from July 1 – July 18th, 2016.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this Motion To Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate.

Respectfully submitted,

Damara H. Watkins

Attorney at Law

1541 Princeton Dr.

Corsicana, TX 75110

Tel: (903) 641-2595

Fax: (903) 872-6456

By: /s/

Damara H. Watkins

State Bar No. 00787740

Attorney for JOSEPH EMMANUEL WATKINS

CERTIFICATE OF SERVICE

This is to certify that on June 29, 2016, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Navarro County, Navarro County Courthouse, 300 W. 3rd Ave., Corsicana, Texas, by electronic service.

/s/

Damara H. Watkins