Joseph Tate Bailey v. State

Opinion

ACCEPTED

01-15-00215-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS 6/15/2015 12:00:00 AM CHRISTOPHER PRINE

CLERK

NO. 01-15-00215-CR

FILED IN

JOSEPH BAILEY 1st COURT OF APPEALS IN THE 1ST COURT OF APPEALS HOUSTON, TEXAS 6/14/2015 3:19:49 PM

VS. HARRIS COUNTY TEXAS CHRISTOPHER A. PRINE

Clerk

THE STATE OF TEXAS HOUSTON, TEXAS

MOTION FOR LEAVE TO FILE FIRST MOTION FOR EXTENSION OF TIME TO

FILE APPELLANT’S BRIEF

TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW LANA GORDON, Appointed counsel for Appellant, JOSEPH

BAILEY, who files this Motion and as grounds therefore would show as follows:

I.

Appellant was convicted by a jury of Murder and was assessed a 35 year sentence.

II.

Appellant’s brief was due June 12, 2015.

Among other matters, professional and personal, Counsel has had numerous felony

briefs and writs recently, including two capital murders, namely, Ex Parte Rodriguez; Ex

Parte January; State of Texas vs. Pena; State of Texas vs.Agado; State of Texas vs.Adekeye.

Further, counsel’s immediate family member has recently suffered serious health

crises lately which counsel primarily assisted with.

IV.

Counsel has filed a Motion for Extension of Time to File Appellant’s Brief along with

this Motion for Leave to File, as it is two days after the due date.

Wherefore, premises considered, Counsel prays that this Honorable Court grant this motion,

grant a 60 day extension and permit the brief to be due on August 12, 2015.

Respectfully Submitted, /s/Lana Gordon Lana Gordon Counsel for Appellant TBN: 08202700 3730 Kirby, Suite 1120 Houston, Texas 77098 TEL: (713) 520-5223 FAX: (713) 520-5455 Email: lanagordonlaw@aol.com

CERTIFICATE OF SERVICE

On this the 14 th day of June, 2015, this Motion was served upon the State of Texas, Harris County District Attorney’s office by e-filing.

/s/ Lana Gordon LANA GORDON