Lakeisha Scott v. State

Opinion

ACCEPTED

01-14-01031-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

4/7/2015 9:40:12 PM

CHRISTOPHER PRINE

CLERK

IN THE COURT OF APPEALS

FOR THE

FIRST COURT OF APPEALS DISTRICT FILED IN

1st COURT OF APPEALS

HOUSTON, TEXAS

LAKEISHA SCOTT § 4/7/2015 9:40:12 PM

APPELLANT § CHRISTOPHER A. PRINE

VS. § Clerk § CASE NO. 01-14-01031-CR THE STATE OF TEXAS § APPELLEE §

MOTION FOR EXTENSION OF

TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE COURT OF APPEALS:

Marcus J. Fleming, counsel for appellant, LAKEISHA SCOTT, makes this motion per Rule 73 and 74(n) of the Texas Rules of Appellate Procedure and moves this Court for an extension of time to file appellant's brief. In support of this motion, appellant shows:

I.

Jurisdiction of this Court is invoked under Tex. R. App. P. 73(a), as an appeal from a conviction entered by the 263RD District Court of Harris County and styled, The State of Texas v. LAKEISHA SCOTT, in cause no. 1387553.

II.

The court’s record has been filed. Counsel has requested one previous extension of time to file appellant's brief.

III.

The Texas Rules of Appellate Procedure provide that this Court may grant a request for an extension of time to file appellant's brief, upon a showing of a reasonable explanation of the need for time. Tex. R. App. 73(n).

IV.

Counsel for appellant has been required to attend to numerous cases in and out of the courtroom which required a great deal of attention. Counsel is currently preparing for the following jury trials scheduled to begin Wednesday, April 8, 2015, in Harris County, Texas: - State vs. Joe Ramirez; Cause no. 1437121; 177th District Court;

-State vs. Arturo Arroyo; Cause no. 1411677; 177th District Court; and -State vs. Harold Henderson; Cause no. 1437039; 177th District Court.

Counsel is also researching and briefing a brief for a murder trial:

-Omar Ibrahim vs. State of Texas; 1-14-00785-CR (Murder).

The requested extension of time in which to file appellant's brief is necessary to adequately represent appellant by insuring that counsel has fully researched the law and issues applicable to this appeal. This motion is neither frivolous nor filed for the purpose of delay but is filed so that the interests of justice may be served and that no rights and privileges of appellant are harmed and prejudiced but are adequately protected.

PRAYER

Counsel for appellant prays the Court to grant permission for a thirty (30) day extension of time to file appellant's brief beyond the filing date of this motion.

Respectfully submitted,

/s/ Marcus J. Fleming

Marcus J. Fleming

State Bar No. 00784058

9219 Katy Freeway, Suite 220 Houston, Texas 77024

(713) 224-1970 Phone

(832) 649-3932 Fax