Quinton Shandra Jones v. State

Opinion

ACCEPTED

14-15-00612-CR

FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS

11/19/2015 2:32:10 PM

CHRISTOPHER PRINE

CLERK

No. 14-15-00612-CR

In the Fourteenth Court of Appeals, FILED IN 14th COURT OF APPEALS

Houston, Texas HOUSTON, TEXAS 11/19/2015 2:32:10 PM

CHRISTOPHER A. PRINE

Clerk

QUINTON SHANDRA JONES,

Appellant

v.

THE STATE OF TEXAS

Appellee

Appellant’s First Motion for Extension of Time to File Brief

Respectfully Submitted by:

Joseph Kyle Verret THE LAW OFFICE OF KYLE VERRET, PLLC Counsel for Appellant TBN: 240429432 11200 Broadway, Suite 2743 Pearland, Texas 77584 Phone: 281-764-7071 Fax: 281-764-7071 Submitted: Email: kyle@verretlaw.com November 19, 2015

No. 14-15-00612-CR

In the Fourteenth Court of Appeals, Houston, Texas

QUINTON SHANDRA JONES,

Appellant

v.

THE STATE OF TEXAS

Appellee

Comes now, Appellant, by and through his undersigned counsel, in the above styled cause and moves this Honorable Court to extend the time for the filing of Appellant's Brief. Per Texas Rule of Appellate Procedure 10.5(b), Appellant provides the following:

Current Deadline for Filing: November 19, 2015 Length of Extension Sought: Thirty (30) Days Number of Previous Extensions Granted: None. Basis for Extensions:

Appellant's counsel is a solo practitioner with a busy criminal and juvenile defense caseload, which requires regular appearances in court on the part of counsel.

Also, in the past thirty days, since the complete record was filed in this cause, counsel has prepared for and tried two felony jury trials:

1) A juvenile Assault on a Public Servant, in County Court at Law No. 1, Cause JV20471, which began on October 26, 2015 2) A first degree Aggravated Assault on a Public Servant, and state jail evading arrest, in the 10th District Court of Galveston County, Texas, which began on November 9, 2015, in Causes 13-CR-2885 and 11-

CR-2236.

Counsel for Appellant seeks this extension of time to be able to prepare a cogent and succinct brief to aid this Court in its analysis of the issues presented. This request is not sought for delay but so that justice may be done.

All facts recited in this motion are within the personal knowledge of the counsel signing this motion, therefore no verification is necessary under Rule of Appellate Procedure 10.2.

PRAYER FOR RELIEF

For the reasons set forth above, Appellant requests that this Court grant this Appellant’s First Motion to Extend Time to File Appellant’s Brief and extend the Deadline for Filing the Appellant’s Brief up to and including December 21, 2015. Appellant prays all other relief to which he may be entitled. Respectfully submitted, /s/ Joseph Kyle Verret Joseph Kyle Verret THE LAW OFFICE OF KYLE VERRET, PLLC Counsel for Appellant TBN: 240429432 11200 Broadway, Suite 2743 Pearland, Texas 77584 Phone: 281-764-7071 Fax: 281-764-7071 Email: kyle@verretlaw.com

Certificate of Service

I certify that a true and correct copy of the foregoing Appellant's First Motion for Extension of Time to File Brief was served on this 19th day of November, 2015, on the Counsel for the Appellee, David Bosserman, at davidb@brazoria-county.com, at the Brazoria County Criminal District Attorney’s Office by e-service through electronic filing.

/s/ Joseph Kyle Verret Joseph Kyle Verret TBN: 2402932