Lydia Metcalf v. State

CourtCourt of Appeals of Texas
DecidedApril 3, 2018
Docket06-17-00211-CR
StatusPublished

This text of Lydia Metcalf v. State (Lydia Metcalf v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lydia Metcalf v. State, (Tex. Ct. App. 2018).

Opinion

ACCEPTED 06-17-00211-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 4/3/2018 1:55 PM DEBBIE AUTREY CLERK

IN THE SIXTH COURT OF APPEALS ___________________________________ FILED IN 6th COURT OF APPEALS NO. 06-17-00211-CR TEXARKANA, TEXAS ___________________________________4/3/2018 1:55:12 PM DEBBIE AUTREY LYDIA METCALF, Appellant Clerk

V.

STATE OF TEXAS, Appellee ____________________________________________________________

On Appeal from the 123rd Judicial District Court Panola County, Texas Trial Court Case No. 2015-C-0290 ___________________________________________________________

APPELLANT’S UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF ___________________________________________________________

William J. Robertson State Bar No. 17077500 9800 Northwest Freeway Suite 314 Houston, Texas 77092 (713) 263-9911 Tele. (866) 657-5609 Fax Robertsonlawfirm@gmail.com John C. Osborne TBA 15333200 7887 Katy Freeway, $184 Houston, Texas 77024 Tele: 713-530-3481 Email: itcprojectfunding@gmail.com ATTORNEYS FOR APPELLANT

1 IN THE SIXTH COURT OF APPEALS ___________________________________

NO. 06-17-00211-CR ___________________________________

LYDIA METCALF, Appellant

STATE OF TEXAS, Appellee ____________________________________________________________

On Appeal from the 123rd Judicial District Court Panola County, Texas Trial Court Case No. 2015-C-0290 ___________________________________________________________

APPELLANT’S UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF ___________________________________________________________

To the Honorable Justices of the Sixth Court of Appeals:

Appellant, Lydia Metcalf, respectfully request the Court to extend the

deadline for filing her Appellant’s Brief by 30 days from April 6, 2018 to

May 6, 2018 pursuant to the Texas Rules of Appellate Procedure 10.5 (b)

and 38.6 (d), and in accordance with the local rules of this Honorable Court.

In support thereof, the Appellees would show as follows:

1. The Appellant requests a thirty-day extension of time for the

deadline for filing the Appellant’s Brief such that the Brief is considered

timely filed on May 6, 2018.

2 2. The undersigned counsel is facing severe time constraints for

reviewing the Reporter’s Record and the file in this appeal and preparing a

complete and proper Appellant’s Brief while at the same time complying

with pre-existing deadlines in other cases.

3. Further, the undersigned counsel for Appellant has been

undergoing chemotherapy at M.D. Anderson Hospital in Houston, Texas for

the last four months which has resulted in delays preparing the Appellant’s

Brief in this cause of action. The undersigned counsel was released from

further treatments at M.D. Anderson on March 28, 2018 but will need

additional time to review the evidence, review the Reporter’s Record and

research the legal issues presented in this case.

4. No previous extensions have been granted or requested

regarding the filing of Appellant’s Brief.

5. The undersigned counsel contacted counsel for Appellee on

April 3, 2018 and Appellee’s counsel is not opposed to this Motion for

Extension of Time to file Appellant’s Brief.

6. Based on the foregoing, Appellant respectfully prays that this

Court extend the deadline for filing the Appellant’s Brief by thirty days from

April 6, 2018 to May 6, 2018.

3 Respectfully submitted,

/s/ William J. Robertson _________________________ William J. Robertson TBA 17077500 9800 Northwest Freeway Suite 314 Houston, Texas 77092 Tele: 713-263-9911 Fax: 866-657-5609 Email: robertsonlawfirm@gmail.com John C. Osborne TBA 15333200 7887 Katy Freeway, $184 Houston, Texas 77024 Tele: 713-530-3481 Email: itcprojectfunding@gmail.com ATTORNEYS FOR APPELLANT

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the above Appellant’s Unopposed First Motion for Extension of Time to file Appellant’s Brief” was served on all counsel of record by U.S. Mail, Certified, Return Receipt Requested and/or by facsimile and/or email and/or the Court’s electronic notification service on this 3rd day of April 2018.

Ms. Gena Bunn P.O. Box 6150 Longview, Texas 75608 Email: gbunn@genabunnlaw.com

/s/ William J. Robertson ________________________ William J. Robertson

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Bluebook (online)
Lydia Metcalf v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lydia-metcalf-v-state-texapp-2018.