Miko Deyond Parks v. State

Opinion

ACCEPTED

12-15-00043-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

6/15/2015 10:05:11 AM

CATHY LUSK

CLERK

NO. 12-15-00043-CR

FILED IN

12th COURT OF APPEALS

STATE OF TEXAS § IN THE TYLER, TEXAS § 6/15/2015 10:05:11 AM VS. § TWELFTH COURT CATHY S. LUSK § Clerk MIKO PARKS § OF APPEALS

SECOND MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Miko Parks, Appellant in the above styled and numbered cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following:

1. This case is on appeal from the 159th Judicial District Court of Angelina County, Texas.

2. The case below was styled the STATE OF TEXAS vs. Miko Parks, and numbered 2014-0129.

3. Appellant was convicted of Possession of Marijuana and Possession of Controlled Substance.

4. Appellant was assessed a sentence of nine years eleven months incarceration in the Texas Department of Criminal Justice Institutional Division on January 30, 2015.

5. Notice of appeal was given on February 2, 2015.

6. The clerk's record was filed on March 31, 2015; the reporter's record was filed on April 15, 2015.

7. The appellate brief is presently due on June 15, 2015.

8. Appellant requests an extension of time of 30 days from the present date, i.e. July 15, 2015.

9. One previous extension to file the brief has been received in this cause.

10. Defendant is currently free on bond.

11. Appellant relies on the following facts as good cause for the requested extension:

Counsel has a burgeoning practice. Counsel is preparing numerous felony and misdemeanor cases in Angelina County, Nacogdoches County, Polk County, Trinity County, San Jacinto County, Shelby County, and Cherokee County, Texas. In addition, the Reporter’s Record in this case is very extensive and counsel needs additional time to complete and file Appellant’s Brief.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this Motion To Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate.

Respectfully submitted,

DEATON LAW FIRM

103 East Denman

Lufkin, TX 75901

Tel: (936) 637-7778

Fax: (936) 637-7784

By:

T. Ryan Deaton

State Bar No. 24007095

Attorney for Miko Parks

CERTIFICATE OF SERVICE

This is to certify that on June 15, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Angelina County, Texas, by fax.

T. Ryan Deaton