Larry Joe Jones v. State

Opinion

ACCEPTED 06-15-00124-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 11/9/2015 3:39:58 PM DEBBIE AUTREY CLERK

CAUSE NO. 06-15-00124-CR

LARRY JOE JONES § IN THE SIXTH FILED IN § 6th COURT OF APPEALS TEXARKANA, TEXAS V. § COURT OF APPEALS 11/9/2015 3:39:58 PM § DEBBIE AUTREY STATE OF TEXAS § OF THE STATE OF TEXAS Clerk

MOTION TO EXTEND DEADLINE FOR FILING APPELLANT’S BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW, Larry Joe Jones, the Appellant, in the above styled and numbered

cause, and files this motion for an extension to December 9, 2015, to file the appellate

brief. In support of this motion, appellant shows the following:

I.

The appellant was tried for the offense of Evading Arrest, in Brazos County, Texas,

under Cause Number 14-02769-CRF-85. At the conclusion of the trial, the jury found the

appellant guilty, and he was sentenced to seventy-five years in the Texas Department of

Criminal Justice on May 5, 2015. A timely notice of appeal was filed in this case. The

appellant's brief is due December 9, 2015.

II.

The reason for the extension of the deadline to file the appellant’s brief is based on

the following:

Appellant's counsel is scheduled to go to trial in Cause No. D1GN14000461, in the

261st District Court of Travis County, Texas, on November 16, 2015. Because of preparation for this impending trial, counsel requires some more time to complete a

thorough review and briefing of the issues in this case.

For these reasons, counsel moves that the deadline for the brief be extended until

December 9, 2015.

RESPECTFULLY SUBMITTED,

/s/ David W. Crawford David W. Crawford State Bar No. 24031601 Crawford and Cruz PLLC P.O. Box 1510 Austin, Texas 77806 Telephone (979) 575-9871 Telefacsimile (512) 237-7792 Email: dcrawford@crawfordcruz.com Attorney for Appellant CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing instrument

has been furnished to the Attorney for the State presently assigned to this case, via fax.

Date: November 9, 2015

/s/ David W. Crawford Attorney for Appellant CAUSE NO. 06-15-00124-CR

LARRY JOE JONES § IN THE SIXTH § V. § COURT OF APPEALS § STATE OF TEXAS § OF THE STATE OF TEXAS

ORDER

On this day of ______________, 201___, came to be heard Appellant’s Motion for

Extension of Time to File Appellant’s Brief, and it appears to the court that this motion

should be:

_________ GRANTED

_________ DENIED

IT IS THEREFORE ORDERED that the time for filing the appellant’s brief in Cause No.

06-15-00124-CR ____________ be extended to _______________, 201__.

SIGNED and ENTERED this __ day of ____________, 201__.

__________________________

JUDGE PRESIDING