Karl Patrick Houlditch v. State
Opinion
ACCEPTED
06-14-00207-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
3/20/2015 2:24:35 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00207-CR
FILED IN
IN THE COURT OF APPEALS 6th COURT OF APPEALS TEXARKANA, TEXAS
FOR THE SIXTH APPELLATE DISTRICT OF TEXAS 3/20/2015 2:24:35 PM
AT TEXARKANA DEBBIE AUTREY
Clerk
KARL PATRICK HOULDITCH
vs.
THE STATE OF TEXAS
Appealed from the 71st District Court of Harrison County, Texas Trial Cause No. 13-0263X
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE SIXTH COURT OF APPEALS: COMES NOW KARL PATRICK HOULDITCH, APPELLANT, on appeal in Cause No. 13-0263X, and files this, his First Motion for extension of Time to File Appellate Brief, and pursuant to Rule 10.5(b), TEX. R. APP. PROC., and pursuant to the extension policies of this Court, makes this request to extend filing the brief in this cause and would show as follows:
I.
The Official Court Reporter has filed the Reporter’s record with this Honorable Court. The undersigned has received copies of that record as well
as the Clerk’s Record. The deadline for filing Appellant’s Brief is on or before March 25, 2015.
II.
Appellant requests an additional thirty (30) days in which to complete the research and writing necessary for submission of the brief.
III.
As reasonable explanation for the need for an extension of time Appellant would show as follows:
While counsel for Appellant has devoted time to reading the record, research, and drafting the Brief, the Brief is not yet finished. Moreover, the record is not yet complete, since there is an important exhibit missing, namely, State’s Exhibit No. 1 from the hearing on the Motion to Suppress. Counsel has communicated with the Court Reporter and District Clerk about this problem, and reasonably expects that the Exhibit will be found and supplied, along with a Supplemental Clerk’s Record of additional documents in the appeal. However, as of this date, those matters are not yet resolved.
Appellate counsel has also during the past thirty days devoted his time to other matters in his office, including, but not limited to, the following matters:
Work on Criminal Appeals
Continued correspondence with Appellant and preparation for oral argument
in Esaw Lampkin v. State, Appellate Cause No. 06-14-00024-CR.
Drafting and filing the Brief for Appellant in Cinque Ross vs. the State of Texas, Appellate Cause No. 06-14-00157-CR.
Correspondence with client in Tommy Scott Thomas, Cause No. PD-0057-
15, Petition for Discretionary Review Probate & Estate Work
Cause No. 2015-0031-E In re Estate of Hall: work on inventory and correspondence with heirs Cause No. 2013-0284-P, In re Estate of Bedsole: work on final accounting;
correspondence with client Work on Civil Appeal
Correspondence with client in Cause No. 06-14-00087-CV, In the Interest of J.
M. A. E. W., A Child Child Protective Services Work
CPS conferences, court hearings, correspondence in the following cases:
No. 2015-369-CR, “Interest of D.W. and K.W.”
No. 2015-178-DR, “Interest of X.D.T.”
No. 2013-983-DR, “Interest of K.S., A.C., R.L.C., and R.D.C.”
No. 2014-180-DR, “Interest of K.M. & K.J.”
No. 2014-1405-DR, “Interest of A.R. and F.L.R.”
No. 2014-1596-DR, “Interest of J. S., S. H., AND R. H.”
No. 2014-1776-DR, “Interest of D. N.”
Civil Litigation
Drafting motions, getting settings, correspondence, and/or other activities in following:
Cause No. 2014-2434-CCL2, Pope & Turner, Inc., of Overton vs. John Edward McDade, Jr., et al, pending in County Court at Law No. 2, Gregg County Cause No. CV14-1856, Sacor Financial, Inc., etc. vs. Texas Bank & Trust, pending in 43rd District Court of Parker County, action in garnishment Cause No. S1-122-14, Pegues-Hurst vs. David Williams, Inc; preparation for trial and obtaining default judgment Cause No. 2014-2257-B, Texas Bank & Trust vs. Johnson, working on agreement to conclude litigation Counsel has also spent several hours in conference during each week of the past 30- day period with clients who have consulted with counsel on such diverse areas of law as collections, criminal law, probate, juvenile, and other legal matters.
With a grant of an additional thirty days Appellate counsel plans to finish writing the brief and submit it to the Court, provided the missing exhibit is
supplied and the Supplemental Clerk’s Record is filed.
IV.
There has previously been no motion filed for extension of time, or grants of time extended to Appellant, for the filing of Appellant's brief.
WHEREFORE, PREMISES CONSIDERED, KARL HOULDITCH, Appellant, respectfully requests that this Honorable Court of Appeals will, upon reviewing this Motion, grant the extension of time for filing Appellant's brief as requested herein, and for such other relief to which Appellant may be entitled.
Respectfully submitted,
LAW OFFICES OF LEW DUNN
_/s/ Lew Dunn_
Lew Dunn Attorney at Law
201 E. Methvin, Suite 102 P.O. Box 2226
Longview, Texas 75606
903-757-6711
FAX 903-757-6712
Texas State Bar No. 06244600 ATTORNEY FOR APPELLANT
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion was hand-delivered or sent by first class mail or by electronic transmission to the office of Hon. Tim Cariker, Assistant Criminal District Attorney, Harrison County Courthouse, 200 W. Houston Street, Suite 206, Marshall, Texas 75670 on this 20 day of March, 2015.
/s/_LewDunn_____________
Lew Dunn
COUNSEL FOR APPELLANT
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