Latori Devon Mosley v. State

Opinion

ACCEPTED

12-16-00115-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

9/19/2016 10:14:54 PM

Pam Estes

CLERK

No. 12-16-00115-CR

LATORI DEVON MOSLEY § IN THE COURT OF APPEALS FILED IN

Appellant § 12th COURT OF APPEALS TYLER, TEXAS

§

vs. § 12TH JUDICIAL 9/19/2016 DISTRICT 10:14:54 PM

PAM ESTES

§ Clerk THE STATE OF TEXAS, § Appellee § AT TYLER, TEXAS

APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF ONE DAY REQUEST

TO THE HONORABLE COURT:

Now comes Austin Reeve Jackson, counsel for Appellant in the above entitled and numbered cause, and makes this Motion, and for good cause shows the following:

I.

Appellant’s brief in this matter is due on 19 September 2016. Three prior extensions have been requested.

II.

While working on this case counsel has also been working on approximately 50 open appellate cases in this and other courts to which he has been appointed by Smith County. This has included investigating motions for new trials (looking for and talking with potential witnesses, jail and office visits with new appellate appointments, trial court appearances for the same), requests for and reviews of reporter’s and clerk’s records, research, briefing, review of opinions, investigation of potential PDR issues, etc. While not all of these seventy or so cases have required significant attention from counsel during this time, many of them have which has resulted in counsel having been able to devote the full attention necessary to this case prior to today’s date.

Because of this, counsel was delayed in completing his brief in this matter.

II.

Three prior extensions have been requested and it is respectfully prayed that in the interest of justice, the Court grant this motion.

WHEREFORE, PREMISES CONSIDERED, undersigned counsel respectfully prays that, in accordance with the applicable law, the Court grant this Motion and extend the date by which to file a brief by one day.

Respectfully submitted,

/s/Austin Reeve Jackson

Texas Bar No. 24046139

112 East Line, Suite 310

Tyler, TX 75702

Telephone: (903) 595-6070 Facsimile: (866) 387-0152

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing document was served on counsel for the State by efile concurrently with its filing.

/s/Austin Reeve Jackson