Kevin E. Bromley v. State

Opinion

ACCEPTED

02-17-00252-CR

SECOND COURT OF APPEALS

FORT WORTH, TEXAS

12/19/2017 5:24 PM

DEBRA SPISAK

CLERK

IN THE COURT OF APPEALS

FOR THE SECOND COURT OF APPEALS DISTRICT FORT WORTH, TEXAS

FILED IN

2nd COURT OF APPEALS

KEVIN E. BROMLEY § FORT WORTH, TEXAS APPELLANT § 12/19/2017 5:24:40 PM § DEBRA SPISAK VS. § NO: 02-17-00252-CR Clerk §

THE STATE OF TEXAS § APPELLEE §

APPELLANT=S MOTION FOR EXTENSION OF TIME FOR FILING APPELLANT=S BRIEF

NOW COMES, KEVIN E. BROMLEY, Appellant, by and through his attorney, WES BALL,

and requests that he be granted an extension of time for filing his brief in the above-styled and

numbered cause. As grounds for granting this motion, Appellant states:

The undersigned counsel is responsible for filing the Appellant=s brief in this case. Appellant seeks an extension of sixty (60) days to February 18, 2018. Appellant=s counsel seeks the extension due to a need for this additional time to adequately prepare Appellant=s brief. Due to his caseload in both trial and appellate courts, he has been unable to complete the brief.

Appellant=s brief is currently due on December 20, 2017. The judgment in this cause was entered on July 20, 2017 by the trial judge presiding in the Criminal District Court No. 3 of Tarrant County, Texas. Appellant was convicted of AGG ASSAULT DEADLY WEAPON. Appellant was sentenced to six (6) years confinement in the Institutional Division of the Texas Department of Criminal Justice, probated for 72 months. Appellant is currently out of jail on an appeal bond. Notice of Appeal was entered on July 25, 2017. The cause number in the trial court was 1469526. No extensions of time have been previously granted in this cause. Counsel requests an extension of sixty (60) days. Granting this extension should not cause any delay in the present submission date. Appellant=s counsel is aware of the policy concerning deadlines for filing briefs and the reluctance to grant extensions in the ordinary case. This request is not being made for mere purposes of delay, but so that justice may be done.

APPELLANT’S MOTION FOR EXTENSION OF TIME FOR FILING APPELLANT’S BRIEF PAGE 1 OF 2

WHEREFORE PREMISES CONSIDERED, Appellant prays that this Honorable Court

grant an extension of sixty (60) days for filing his brief on appeal to February 18, 2018.

Respectfully submitted,

/s/ Wes Ball WES BALL State Bar No. 01643100 4025 Woodland Park Blvd., Suite 100 Arlington, Texas 76013 Email: WBnotices@ballhase.com Telephone: (817)860-5000 Fax No.: (817)860-6645

ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

On this the 19th day of December, 2017, a true and correct copy of the above and foregoing

Appellant=s Motion for Extension of Time for Filing Appellant=s Brief was delivered electronically to

the Post-Conviction Division of the Tarrant County District Attorney=s Office.

/s/ Wes Ball WES BALL Attorney for Appellant

CERTIFICATE OF CONFERENCE

On the 18th day of December, 2017, Malinda Davis, assistant to Appellant=s counsel

contacted Cyndi Burgess, assistant to Debra Windsor, Chief of Post-Conviction, Tarrant County

District Attorney=s Office regarding the foregoing Motion and has been advised that the state does

not oppose the Motion.

/s/ Wes Ball______________________________ WES BALL

APPELLANT’S MOTION FOR EXTENSION OF TIME FOR FILING APPELLANT’S BRIEF PAGE 2 OF 2