Joseph Leo Strehl, III v. State

Opinion

ACCEPTED 06-15-00117-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 9/15/2015 5:18:00 PM DEBBIE AUTREY CLERK

Cause No. Q 6-15-001 17—CR JOSEPH STREHLIII § IN THE COURT OF APPEALS § 6TH FILED IN V. § APPELLATE 6thDISTRICT COURT OF APPEALS § TEXARKANA, TEXAS STATE OF TEXAS TEXARKANA,9/16/2015 TEXAS 8:13:00 AM DEBBIE AUTREY MOTION TO EXTEND TIME TO FILE BRIEF Clerk

TO THE HONORABLE JUDGES OF SAID COURT: COMES NOW, Appellant, through JEFF SANDERS, Defense Attorney, in the above

styled and numbered cause and files this Motion and in support thereof would show the Court as

follows:

1. The Appellant’s Brief is due on September 21, 2015. Appellant’s attorney needs 30

additional days to file the brief. This is the first request for an extension.

2. During the past 30 days, Counsel has been preparing for a juvenile discretionary

transfer hearing in Cause Number 003-0157-l5, In the Matter of Q.H., in Smith

County, Texas. Additionally, Counsel has been preparing two cases for client

Thomas Overman on the Rusk County trial docket. One is identified as Cause

Number CR14-334-1 (state jail felony theft) and the other is identified as Cause

Number CRl4—268 (non-compliance with sex offender registration requirements).

I’Ve also been working on and investigating an unindicted aggravated assault charge

in Smith County, styled State V. Lee Matthew Harrell.

3. This motion is not made for purposes of delay, but so that justice may be done. WHEREFORE, PREMISES CONSIDERED, the Appellant requests that this motion for be granted. State Bar Number 24033153 ELLIS and SANDERS PLLC 120 S. Broadway Suite 112 Tyler,Texas 75702 Phone (903)595-1131 Fax (903)595-5532

CERTIFICATE OF SERVICE This a true and correct copy of the foregoin Motion was served upon the attorney is to certify that for the State on 15th of September, 2015.

VERIFICATION STATE OF TEXAS § § KNOW ALL MEN BY THESE PRESENTS COUNTY OF SMITH §

“My name is JEFF SANDERS and I am the attorney for the Appellant in this case. I have

knowledge of the facts stated in the foregoing Motion and they are true and correct.”

Signedon .~Ler /5‘ ,2o15.

/}////aw,- J%1=$%NDERs

SWORN AND J SUBSCRIBED TO BEFORE ME, the undersigned Notary Public on

Qua . / , 2015.

in and folghe State of Texas 2 ""5 “um” My povmmlon Expires mm: 13. 2017