Randy Crawford v. State

Opinion

ACCEPTED

12-15-00176-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

9/22/2015 1:57:17 PM

Pam Estes

CLERK

NO. 12-15-00176-CR

ON APPEAL FROM THE 217TH JUDICIAL DISTRICT COURTFILED IN ANGELINA COUNTY, TEXAS 12th COURT OF APPEALS TYLER, TEXAS

CAUSE NO. 2014-0568 9/22/2015 1:57:17 PM PAM ESTES

TH Clerk

RANDY EARL CRAWFORD § IN THE 12 COURT OF APPEALS § § OF

vs. § §

STATE OF TEXAS § TYLER, TEXAS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Randy Earl Crawford, 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 217th District Court of Angelina County, Texas.

2. The case below was styled the STATE OF TEXAS vs. Randy Earl Crawford, and numbered 2014-0568. Appellant was convicted Theft.

4. Appellant was assessed a sentence of Fifteen (15) years in Texas Department of Criminal Justice Institutional Division on June 25, 2015.

5. Notice of appeal was given on June 26, 2015. 6. The clerk's record was filed on August 24, 2015; the reporter's record was filed on July 7, 2015.

7. The appellate brief is presently due on September 23, 2015. 8. Appellant requests an extension of time of thirty (30) days from the current due date.

9. No extensions to file the brief have been received in this cause. 10. Defendant is currently incarcerated. 11. Appellant relies on the following facts as good cause for the requested extension:

After a series of health issues, counsel has been hospitalized and will not be able to complete the brief by September 23, 2015.

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:

/s/John D. Reeves

____________________

John D. Reeves Attorney at Law 1007 Grant Lufkin, Texas 75901 Phone (936) 632-160 Fax: (936) 632-1640 tessabellus@yahoo.com SBOT # 16723000 Counsel for Appellant

CERTIFICATE OF CONFERENCE

Pursuant to Tex. R. App. 10.1 (5), certify that I, the undersigned conferred with opposing counsel who is not opposed to an extension.

/s/John D. Reeves

___________________________

John D. Reeves

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Appellant’s Motion to Extend Time to file Appellant’s Brief on this 22nd day of September, 2015 forwarded to State’s Attorney, April Ayers-Perez, Angelina County, by electronic service at aprerez@angelinacounty.net.

/s/John D. Reeves

__________________________

John D. Reeves Attorney for Appellant, David Charles Dailey