Quincy Blakely v. State

Opinion

ACCEPTED

05-18-00064-CR

FIFTH COURT OF APPEALS

DALLAS, TEXAS 1/30/2018 4:58 PM

LISA MATZ

CLERK

CASE NO. 05-18-00064-CR

IN THE FIFTH COURT OF APPEALS FILED IN

5th COURT OF APPEALS

DALLAS, TEXAS DALLAS, TEXAS 1/30/2018 4:58:31 PM

__________________________________________________________________

LISA MATZ

Clerk

QUINCY BLAKELY, Appellant V.

THE STATE OF TEXAS, Appellee.

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APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S JURISDICTIONAL LETTER BRIEF

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Quincy Blakely

2701 Little Elm Parkway Ste. 100-551 Little Elm, Texas

TO THE HONORABLE FIFTH COURT OF APPEALS:

NOW COMES Quincy Blakely, Appellant herein, hereby moves this Court to extend

briefing schedule in this proceeding. In support of this motion, Appellant would show as follows:

1. This Court advised the parties on January 23, 2018 to file a jurisdictional letter brief, and

Appellant’s deadline for filing said jurisdictional letter brief in this matter is January 31,

2018 and Appellee’s deadline is February 9, 2018.

2. However, Appellant is seeking counsel in the preparation of the jurisdictional letter

matters and hereby request an extension to properly respond.

3. In light of seeking counsel, and due to the short notice provided for preparing and filing

this jurisdictional brief, Appellant has not yet had an adequate opportunity to properly

prepare the brief to be considered by this Court, and thus, seeks an extension of time to

be able to prepare a cogent and succinct brief to aid this Court in its analysis of the

jurisdictional issues presented, which relate to this Court’s jurisdiction to entertain an

appeal after a Motion to Dismiss for Lack of Subject Matter and Personal Jurisdiction

which was denied.

4. The State of Texas would not suffer any undue hardship or other prejudice as a result of an extension in the present case. This request is sought not for delay, but so that justice may be done.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully moves this Court to

grant the requested Appellant’s First Motion to Extend Time to File Appellant’s

Jurisdictional Letter Brief and reschedule this matter so as to allow Appellant to properly

present his brief to This Court, and to grant any and all relief to which Appellant may be

entitled in law or equity.

/s/ Quincy Blakely 2701 Little Elm Parkway #100-551 Little Elm, Texas blakelyrightsreserved@gmail.com

CERTIFICATE OF SERVICE

I hereby certify that a copy of this Notice of Appeal was served upon the Dallas County District Attorney’s Office via https://efile.txcourts.gov.

/s/ Quincy Blakely