Latori Devon Mosley v. State

• Court: Court of Appeals of Texas
• Decided: September 19, 2016
• Docket: 12-16-00115-CR
• Status: Published

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.

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