Terry Eugene Glenn, Sr. v. State

Opinion

ACCEPTED

061400212CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

4/8/2015 8:15:26 AM

DEBBIE AUTREY

CLERK

NO. 06-14-00212-CR

FILED IN

TERRY EUGENE GLENN, Jr. IN APPEALS OF COURT

THE COURT 6th OF APPEALS TEXARKANA, TEXAS

VS. 4/8/2015 SIXTH APPELLATE 9:00:00 AM DISTRICT

DEBBIE AUTREY

THE STATE OF TEXAS STATE OF TEXAS Clerk

INOTION TO EXTEND TIIIE TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT'

Now comes Terry Glenn, 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 71st Judicial District Court of Harrison County, Texas.

2. The case below was styled the STATE OF TEXAS vs, Ter Eu ene Glenn Jr. , and numbered 12-0455X.

3. Appellant was convicted of possession of a controlled substance.

4. Appellant was assessed a sentence of 15 years on October 8, 2014.

5. Notice of appeal was given on December 2, 2014.

6. The clerk's record was filed on December 15, 2014; the reporter's record

was filed on March 8, 2015.

7. The appellate brief is presently due on April 8, 2015.

8. Appellant requests an extension of time of 20 days from the present date, i.e. April 28, 2015.

9. No previous request for an 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:

The reporter's record was filed on March 8, 2014. Since receiving the record, Appellant's attorney, Laura M. Carpenter, has been called and tried three criminal jury trials. As such, additional time is requested to file Appellant's 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,

LAURA M CARPENTER PLLC

P.O. Box 8286

Marshall, TX 75671

Tel: (903) 938-7440

Fax: (903) 938-3008

By

aura M. Carpente

State Bar No. 08618050

carpenterlaw1 23@sbcglobal. net Attorney for Terry Eugene Glenn, Jr.

CERTIFICATE OF SERVICE

This is to certify that on April 8, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Harrison County, by

electronic service through the Electronic Filing Manager.

L M. Carpenter

STATE OF TEXAS COUNTY OF HARRISON

AFFIDAVIT

BEFORE ME, the undersigned authority, on this day personally appeared Laura M, Carpenter, who after being duly sworn stated:

"I am the attorney for the appellant in the above numbered and entitled cause. I have read the foregoing Motion to Extend Time to File Appellant's Brief and swear that all of the allegations of fact contained therein are true and correct. "

ra M, Carpenter

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME on April 8, 2015, to certify which witness my hand and seal of office,

+»I'~ CRYSTAL GAIL ROSERTS Notary Public, State of Texas MY COMMISSION EXPIRES

' "~ It9 ILt

~ January 5, 2018