Shadondra Jenkins v. State

• Court: Court of Appeals of Texas
• Decided: January 7, 2015
• Docket: 12-14-00295-CR
• Status: Published

Opinion

ACCEPTED 12-14-00295-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 1/7/2015 3:35:26 PM CATHY LUSK CLERK

NO. 12-14-00295-CR

ON APPEAL FROM THE 159TH JUDICIAL DISTRICT COURTFILED IN ANGELINA COUNTY, TEXAS 12th COURT OF APPEALS TYLER, TEXAS CAUSE NO. 2013-0615 1/7/2015 3:35:26 PM CATHY S. LUSK TH Clerk SHADONDRA JENKINS § 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 Shadondra Jenkins, 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 159th District Court of Angelina County, Texas. 2. The case below was styled the STATE OF TEXAS vs. Shadondra Jenkins, and numbered 2013-0615. 3. Appellant was convicted of two counts of Injury to a Child. 4. Appellant was assessed a sentence of One hundred and fourteen months Texas Department of Criminal Justice Institutional Division on October 2, 2014. 5. Notice of appeal was given on October 9, 2014. 6. The clerk's record was filed on November 4, 2014; the reporter's record was filed on December 9, 2014. 7. The appellate brief is presently due on January 8, 2014. 8. Appellant requests an extension of time of thirty (30) days from the present date, i.e. January 8, 2015. 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: In addition to the holiday schedule, Counsel for appellant has been court appointed on three pending appeals, which includes the above captioned brief in Angelina County and one appeal pending in Trinity County and requests additional time to complete his review of the records and prepare the brief. 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 the staff of the undersigned conferred with opposing counsel who indicated that she does not oppose this motion. /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 First Motion to Extend Time to file Appellant’s Brief on this 7h day of January, 2015 forwarded to State’s Attorney, April Ayers-Perez, Assistant District Attorney, Angelina County, by electronic service at aperez@angelinacounty.net.

/s/John D. Reeves __________________________ John D. Reeves Attorney for Appellant, Shadondra Jenkins