Shahid Karriem Ansari, III v. State

Opinion

ACCEPTED

06-14-00220-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

7/22/2015 11:00:55 PM

DEBBIE AUTREY

CLERK

NO. 06-14-00220-CR

SHAHID KARRIEM ANSARI § IN THE FILED IN 6th COURT OF APPEALS

§ TEXARKANA, TEXAS § 7/22/2015 11:00:55 PM VS. § 6TH COURT OF APPEALS DEBBIE AUTREY

§ Clerk STATE OF TEXAS § TEXARKANA

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF, 2ND TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Shahid Karriem Ansari III, 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 354TH Judicial District Court of Hunt County, Texas.

2. The case below was styled the STATE OF TEXAS vs. Shahid Karriem Ansari III, and numbered 27,739.

3. Appellant was convicted of Burglary of a Habitation.

4. Appellant was assessed a sentence of 7 years on November 20, 2014.

5. Notice of appeal was given on November 26, 2014.

6. The clerk's record was filed on March 26, 2015; the reporter's record was filed on May 21, 2015.

7. The appellate brief is presently due on July 22, 2015.

8. Appellant requests an extension of time of 30 days from the present date.

9. One extension to file the brief has been received in this cause.

10. Defendant is currently incarcerated.

11.Appellant relies on the following facts as good cause for the requested extension:

Appellant’s attorney, Jason A. Duff has begun a review the several volumes in the reporter’s record and the clerk’s record the record; however, Appellant’s counsel requests additional time to sufficiently develop the arguments material to the brief. Counsel is also appointed in: James Wayne Walsh v. The State of Texas, Appellate Case Number: 06-14- 00059-CR and timely filed a brief on July 22, 2015. Mark Eugene Engle v. The State of Texas, Appellate Case Number: 06-14- 00239-CR and timely filed a brief on July 22, 2015. Charles Francis Williams v. The State of Texas, Appellate Cause Numbers: 06-15-00030-CR and 06-15-00031 with a brief due August 12, 2015. Pamela Diane Contreras v. The State of Texas, Appellate Case Number: 05- 15-00544-CR.

Counsel prepared for and represented his clients for a Temporary

Restraining Order hearing that was heard over two days involving the removal of children related to a petition for Termination of Parental rights in In the Interest of S.H. and J.H. in Cause No. 81,969 in the 196th District Court on July 9 and 10, 2015.

Counsel prepared for and will represent his clients in Adversarial hearings in Hunt County Child Protection Court for Northeast Texas #2 on July 10, 2015 , on July 15, 2015, and on July 24, 2015 in several separate cases. 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,

JASON A DUFF

2615 Lee St.

P.O. Box 11

GREENVILLE, TX 75403

Tel: 903.455.1991

Fax: 903.455.1417

By: /s/ Jason A. Duff

Jason A. Duff

State Bar No. 24059696

jasonaduff@hotmail.com

Attorney for Shahid Karriem Ansari

III

CERTIFICATE OF SERVICE

This is to certify that on July 22, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Hunt County, by electronic service through the Electronic Filing Manager.

/s/ Jason A. Duff

Jason A. Duff