Nick N.Feizy v. State

Opinion

ACCEPTED

06-14-00230-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS 3/24/2015 11:49:12 AM

DEBBIE AUTREY

CLERK

NO. 06-14-00230-CR

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FILED IN

6th COURT OF APPEALS

TEXARKANA, TEXAS

IN THE SIXTH DISTRICT COURT OF APPEALS 3/24/2015 11:49:12 AM

TEXARKANA, TEXAS DEBBIE AUTREY Clerk

_______________________________________________________

NICK FEIZY,

Appellant,

v.

STATE OF TEXAS,

Appellee.

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

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TO THE HONORABLE COURT OF APPEALS:

1. Appellant’s Brief is due on April 9, 2015. Appellant seeks a 30-day

extension to make the brief due on May 9, 2015.

2. This is the first request for an extension.

3. The undersigned counsel knows this Court expects attorneys to file

briefs when they are due. This is an exceptional case. The undersigned, a sole

practitioner, has briefs on the merits in two separate cases before the Supreme

MOTION FOR EXTENSION PAGE 1

Court of Texas, due on April 6 (No. 14-0591) and April 9 (No. 14-0732),

respectively. This is in addition to counsel’s usual March workload (which

included a motion for rehearing in the Texas Supreme Court, two oral arguments,

an Appellant’s Brief, a federal 12(b)(6) motion, a federal summary judgment

response, and error preservation research in preparation for a March 30 trial

setting). Preparing the two merits briefs for the Supreme Court has, quite simply,

overwhelmed counsel.

4. Appellee does not oppose this motion.

Based on the foregoing, Appellant asks that the deadline to file his brief be

extended to May 9, 2015.

Respectfully submitted,

/s/Charles “Chad” Baruch The Law Office of Chad Baruch Texas Bar Number 01864300 3201 Main Street Rowlett, Texas 75088 Telephone: (972) 412-7192 Facsimile: (972) 412-4028 E-Mail: baruchEsq@aol.com

Attorney for Appellant

MOTION FOR EXTENSION PAGE 2

CERTIFICATE OF CONFERENCE

The undersigned certifies that he conferred with John Rolater, counsel for appellee, who stated that he does not oppose the relief sought by this motion.

/s/Charles “Chad” Baruch

CERTIFICATE OF SERVICE

The undersigned certifies that a true and correct copy of this instrument was served upon all counsel of record by e-filing and by email to jrolater@co.collin.tx.us on March 24, 2015.

/s/Charles “Chad” Baruch

MOTION FOR EXTENSION PAGE 3