Robert Lee Burnett v. State

Opinion

ACCEPTED 01-15-00666-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 12/4/2015 1:01:58 PM CHRISTOPHER PRINE CLERK

CAUSE NO. 01-15-00666-CR

ROBERT LEE BURNETT § INFILED THEINFIRST 1st COURT OF APPEALS § HOUSTON, TEXAS V. § COURT OF 1:01:58 12/4/2015 APPEALSPM § CHRISTOPHER A. PRINE THE STATE OF TEXAS § HOUSTON, Clerk TEXAS

THIRD UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE JUSTICES OF THE COURT:

ROBERT LEE BURNETT, Appellant in the above referenced cause, files

this, his Second Unopposed Motion to Extend Time to File Appellant’s Brief,

pursuant to the Texas Rules of Appellate Procedure, and would show as follows:

1. This is an appeal from the 506th Judicial District Court of Grimes

County, Texas. The trial court cause assigned this matter Cause Number 17,685.

2. Appellant respectfully requests a seven (7) day extension, until

December 14, 2015, in which to file his Appellant’s Brief. This is Appellant’s

third request for an extension of time in which to file his brief.

3. In this cause, a jury convicted BURNETT of failure to comply with

registration requirements. The Trial Court subsequently sentenced him to sixty

years in the Institutional Division of the Texas Department of Criminal Justice.

4. The trial court filed the clerk’s record with the Court on August 4,

2015.

5. Appellant’s brief is due on Monday, December 7, 2015. 6. On November 16, 2015, the undersigned completed and filed one of

the parent’s briefs in Case No. 14-15-00644-CV; In the Interest of M.G., B.G.,

M.S.G., and A.Z.; in the Fourteenth Court of Appeals of Houston, Texas, the

involuntary termination of parental rights case referenced in the Appellant’s

second unopposed motion for an extension. Since that filing, the undersigned has

been working to finish reading the reporter’s record in the instant matter as well as

conducting the legal research necessary to complete Appellant’s brief. Moreover,

several matters which the undersigned had “put-off” while completing the

aforementioned brief needed the undersigned’s time and attention over the last two

weeks. Accordingly, good cause exists for the short, seven (7) day, extension

sought herein.

7. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this

Court grant this motion for an extension of time.

Respectfully submitted,

CLOVER & MARAK PLLC

By: /s/ Joshua S. Clover Joshua S. Clover State Bar No. 24045668 josh@clovermarak.com P.O. Box 2548 Brenham, Texas 77834 979-836-7733 888-227-1147 (fax) ATTORNEY FOR APPELLANT

2 CERTIFICATE OF CONFERENCE

I certify that today, December 4, 2015, I conferred with counsel for the State who indicated he was unopposed to the extension of time requested in this motion.

/s/ Joshua S. Clover Joshua S. Clover

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Third Unopposed Motion to Extend Time to File Appellant’s Brief has been served to all counsel of record in the manner indicated below on this the 4th day of December, 2015:

Via Facsimile: (936) 873-2688 Tuck McLain District Attorney Grimes County P.O. Box 599 Anderson, Texas 77830