Steven Lamon Moore v. State

Opinion

ACCEPTED 12-15-00195-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 10/20/2015 4:51:30 PM Pam Estes CLERK NO. 12-15-00195-CR

STEVEN LAMON MOORE § IN THE COURT OF APPEALS § FILED IN vs. § 12th TWELFTH JUDICIAL COURT OF APPEALS DISTRICT TYLER, TEXAS § STATE OF TEXAS § TYLER, TEXAS 10/20/2015 4:51:30 PM PAM ESTES Clerk MOTION TO RECALCULATE DATES FOR FILING THE APPELLANT’S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes 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 7th Judicial District Court of Smith County,

Texas.

2. The case below was styled State v. Steven Lamon Moore and numbered 007-

0446-15.

3. Appellant was convicted of Manufacture/Delivery of a Controlled Substance.

4. Appellant was assessed a sentence of thirty-five (35) years confinement in the

Texas Department of Criminal Justice-Institutional Division.

5. Notice of Appeal was given on August 5, 2015.

6. The Clerk's Record was filed on September 17, 2015; Jennifer Lowrance and

Beverly Dixon’s Reporters’ Records were filed on September 30, 2015. At the

time of this Motion, the Appellant has filed a Motion to Supplement with the

Twelfth Court of Appeals requesting the Pre-Sentence Investigation Report.

The Appellant’s brief is due November 2, 2015. However, this calculation was

made prior to the needing the supplementation of the Clerk Record. Counsel

requests the Court recalculate the brief deadline based on 30 days following the

completion of the record in this case. TEX. R. APP. P. 38.6.

7. Appellant requests that the Court grant this Motion and recalculate the deadline dates for filing the Appellant’s Brief and further relief as the Court

may deem appropriate.

Respectfully submitted,

Law Office of James W. Huggler, Jr. 100 E. Ferguson, Suite 805 Tyler, Texas 75702 Tel: (903) 593-2400 Fax: (903) 593-3830

By: /S/ James W. Huggler, Jr. James W. Huggler, Jr. State Bar No. 00795437 Attorney for APPELLANT

CERTIFICATE OF SERVICE

This is to certify that on October 20, 2015, a true and correct copy of the above

and foregoing document was served on Michael West, Smith County District Attorney's

Office, 100 North Broadway, Tyler, Texas 75702, by regular mail, fax, hand delivery,

or electronic filing.

/S/ James W. Huggler, Jr. James W. Huggler, Jr.