Quinton Shandra Jones v. State

• Court: Court of Appeals of Texas
• Decided: November 19, 2015
• Docket: 14-15-00612-CR
• Status: Published

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

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