Michael Don Denton v. State

Opinion

ACCEPTED 07-15-00181-CR SEVENTH COURT OF APPEALS AMARILLO, TEXAS 7/20/2015 5:05:45 AM Vivian Long, Clerk

NO. 07-15-181-CR

MICHAEL DON DENTON § IN THE COURT OF APPEALS FILED IN 7th COURT OF APPEALS § AMARILLO, TEXAS v. § OF7/20/2015 TEXAS5:05:45 FOR AM THE § VIVIAN LONG THE STATE OF TEXAS § SEVENTH JUDICIALCLERK DISTRICT

MOTION TO EXTEND TIME TO FILE THE APPELLANT’S BRIEF, BY 45 DAYS TO THE HONORABLE JUDGES OF THIS COURT:

COMES NOW Michael Don Denton, Appellant in the above-entitled and

numbered cause, and moves the Court to extend time to file the brief by 45 days. In

support thereof, Appellant respectfully shows the Court the following:

I.

Undersigned counsel apologizes to the Court for his neglect of the brief. He

mistakenly assumed the jurisdictional issue raised in this case would be decided

before briefing would begin, and did not keep up with the schedule set by the

Court. No prior extensions have been sought or granted.

II.

The reasons for this request are as follows. In addition to the circumstances

noted in the paragraph above, counsel is currently in London on an annual

international excursion. He is scheduled to return to Amarillo on August 10, 2015. In addition, counsel would have had insufficient time to prepare the brief

before he left on July 16, 2015. In the thirty days preceding this Motion, counsel

has filed the following extensive documents in addition to representing parole

clients in Lubbock County:

Thomas v. State, 07-14-418/9-CR – opening brief filed 6/29/15 In re R.A.J., 10,253-J#1 (Potter County) – writ application filed 7/10/15 Finch v. State, 07-15-104-CR – opening brief filed 7/15/15

WHEREFORE, the appellant prays the Court extend the time for filing the

brief to August 24, 2015.

Respectfully submitted, /s/ JOHN BENNETT John Bennett P.O. Box 19144 Amarillo, TX 79114 (806) 282-4455 Fax: (806) 398-1988 State Bar Number 00785691 Attorney for the Appellant appealsattorney@gmail.com

CERTIFICATE OF SERVICE

This is to certify that a copy of the above Motion was served on Warren

Clark, Esq., Randall County Assistant Criminal District Attorney, by email to him

at wclark@randallcounty.org on July 20, 2015.

/s/ JOHN BENNETT John Bennett