Lashonda Deon Jones v. State

Opinion

ACCEPTED 14-15-00300-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 8/28/2015 3:22:06 PM CHRISTOPHER PRINE CLERK

CASE NO. 14-15-00300-CR CASE NO. 14-15-00301-CR FILED IN 14th COURT OF APPEALS LASHONDA DEON JONES § IN THE COURTHOUSTON, OF APPEALSTEXAS § 8/28/2015 3:22:06 PM v. § 14th DISTRICT CHRISTOPHER A. PRINE § Clerk THE STATE OF TEXAS § HOUSTON, TEXAS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

LASHONDA DEON JONES, Appellant in the above styled and numbered case, moves

this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the

Texas Rules of Appellate Procedure, and for good cause shows the following:

1. This case is on appeal from 221 st Judicial District Court in Montgomery County

Texas.

2. The case below was styled The State of Texas vs. LASHONDA DEON JONES,

and numbered 15-01-00219-CR.

3. Appellant was convicted of Possession of a Controlled Substance and Tampering

with Physical Evidence.

4. On January 29, 2015, Appellant was assessed a sentence to forty-five (45) years

in the Texas Department of Criminal Justice, Institutional Division on each charge to run

concurrent.

5. Notice of appeal was given on February 18, 2015.

6. The Clerk's Record was filed on May 28, 2015. The Reporter's Record was filed

on May 13, 2015.

7. The appellate brief is presently due on August 28, 2015.

LASHONDA DEON JONES V. THE STATE OF TEXAS MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF Page 1 of 4 8. Appellant requests an extension of time of 30 days from the present date, i.e.

September 21, 2015.

9. One extension to file the brief has been received in this cause.

10. Appellant is currently incarcerated.

11. Appellant relies on the following facts as good cause for the requested extension.

The record in this case consists of 9 volumes consisting of Pre-Trial

hearings, voir dire, guilt/innocence phase, punishment phase and exhibits.

Due to the nature and severity of the sentence due diligence is required to

properly prepare a brief on this matter.

I have completed reviewing the record and identified numerous grounds

that require further research and writing in order to properly represent Appellant.

LASHONDA DEON JONES PRAYS that this Court grant this Motion to Extend Time to

File Appellant's Brief.

Respectfully submitted,

Law Offices of Austin D. Black 215 Simonton Conroe, Texas 77301 936-524-3124 936-756-3539 facsimile

By: Austin D. Black State Bar No. 24050018 Attorney for LASHONDA DEON JONES

LASHONDA DEON JONES V. THE STATE OF TEXAS MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF Page 2 of 4 CERTIFICATE OF SERVICE

This is to certify that on August 28, 2015 , a true and correct copy of the above and foregoing document was served on the Montgomery County District Attorney's Office by e-file.

Austin D. Black

LASHONDA DEON JONES V. THE STATE OF TEXAS MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF Page 3 of 4 STATE OF TEXAS

COUNTY OF MONTGOMERY

AFFIDAVIT

BEFORE ME, the undersigned authority, on this day personally appeared Austin D.

Black, who after being duly sworn stated:

"I the attorney for the appellant in the above numbered and styled cause. I have read the foregoing Motion to Extend Time to File Appellant's Brief and swear that all of the allegations of fact contained therein are true and correct to the best of my knowledge."

Austin D. Black Affiant

SUBSCRIBED AND SWORN TO BEFORE ME on

L.A.9a9A-- s6 apc to certify which witness my hand and seal of office.

Z:FF;;:',,, STEPHANIE D. BLACK l'::A4411: Notary Public, State of Texas lic, State of Texas My Commission Expires ........ November 08, 2017

LASHONDA DEON JONES V. THE STATE OF TEXAS MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF Page 4 of 4