Marquis Jamal Reed v. State

Opinion

ACCEPTED

06-17-00203-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

6/6/2018 3:01 PM DEBBIE AUTREY

CLERK

IN THE

COURT OF APPEALS

SIXTH DISTRICT OF TEXAS AT TEXARKANA FILED IN

6th COURT OF APPEALS

TEXARKANA, TEXAS

NO. 06-17-00203-CR 6/6/2018 3:01:17 PM DEBBIE AUTREY

Clerk

MARQUIS JAMAL REED, Appellant vs.

THE STATE OF TEXAS, Appellee

MOTION FOR EXTENSION OF TIME TO FILE APPEAL BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

COMES NOW, MARQUIS JAMAL REED, the Appellant in the above entitled and numbered cause, by and through her attorney of record, Toby C. Wilkinson, and files her Motion for Extension of Time to File Appeal Brief in the above entitled and numbered cause, and would show unto this Honorable Court the following:

I.

Movant’s Appeal Brief is due for filing on or before June 6, 2018.

II.

This is Movant’s second request for extension in this cause.

III.

Movant requests an extension of time within which to file his Appeal Brief, and as reason therefore would show the Court as follows:

Movant would show that his attorney received an extension to file his Brief on or before June 6, 2018. His attorney inadvertently read the letter as July 6, 2018. The attorney would show that he was working on a Capital Murder Trial and Jury Selection begins in July, 2018.

IV.

Attorney would show he discovered this error working on the Brief today when he discovered this error.

V.

Movant’s attorney would show that the Appellant’s trial was approximately a week long and the transcript covers numerous volumes.

VI.

The undersigned counsel respectfully requests this Honorable Court to extend the time of filing of Movant’s Appeal Brief to June 13, 2018.

WHEREFORE, PREMISES CONSIDERED, TOBY C. WILKINSON prays that this Honorable Court grant Movant's Motion for Extension of Time in this cause.

Respectfully submitted,

Toby C. Wilkinson Toby C. Wilkinson Law Office of Toby C. Wilkinson, P.C. P.O. Box 324 2815 Wesley Street Greenville, Texas 75403-0324 (903) 454-6096 (903) 454-0446 Fax SBA #21497300 Attorney for Marquis Jamal Reed, Appellant

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above and foregoing Motion for Extension of Time to File Appeal Brief has been delivered to all attorneys of record this the 6th day of June 2018.

Toby C. Wilkinson Toby C. Wilkinson