Willie Frank Jackson v. State

• Court: Court of Appeals of Texas
• Decided: December 29, 2014
• Docket: 06-14-00097-CR
• Status: Published

Opinion

ACCEPTED 06-14-00097-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/29/2014 3:43:27 PM DEBBIE AUTREY CLERK

NO. 06-14-00097-CR FILED IN 6th COURT OF APPEALS STATE OF TEXAS § IN THE TEXARKANA, TEXAS § 12/29/2014 3:43:27 PM VS. § 6th COURT DEBBIE AUTREY § Clerk WILLIE FRANK JACKSON § OF APPEALS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Willie Frank Jackson, 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. Willie Frank

Jackson, and numbered 29,295.

3. Appellant was convicted of Aggravated Robbery, with a Deadly

Weapon.

4. Appellant was assessed a sentence of 90 years on May 14, 2014.

5. Notice of appeal was given on May 14, 2014.

6. The clerk's record was filed on September 10, 2014; the reporter's record was filed on November 25, 2014.

7. The appellate brief is presently due on December 29, 2014.

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

date.

9. No 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 reporters record as well as the clerks record the record; but, Appellant’s counsel

requests additional time to sufficiently develop the arguments material to the brief.

Additionally, Counsel was on vacation from the afternoon of December 24,

2014 through December 28, 2014.

Counsel is also appointed in:

Garza v. State Appellate Cause numbers 06-14-00088-CR through

06-14-00093, and filed multiple briefs relating to that case December 22, 2014,

Counsel is appointed in Semaj Milan Yrnah Smith v. State, Appellate Cause

No. 06-14-00158-CR and filed a brief on December 23, 2014,

Young v. State Appellate Cause number 06-14-00086-CR with a brief also due

on December 29, 2014, Donny Joe Curry v. State Appellate Cause numbers 06-14-00139-CR thru

06-14-00142-CR with a brief due December 29, 2014.

Bennett v. State Cause number 06-14-00050-CR where Appellant’s attorney

filed a brief on November 17, 2014 and is awaiting Appellee’s brief,

AND

Grubbs v. State Appellate Cause numbers 06-14-00116-CR &

06-14-00117-CR and is awaiting the Reporter’s record.

Appellant counsel’s represented his client at trial in Cause No. CC1400383

Jim Lee Odom v. Troy Morrison in County Court at Law No. 2 of Hunt County

Texas on December 16, 2014

Then counsel participated settlement conferences in Cause No. 80,433 ITIO

of L.W. and Cause No. 80219, ITIO M.S. E.S and B.M. on December 2, 2014. After

the parties failed to reach a settlement in Cause No. 80219, ITIO M.S. E.S and B.M.

on December 2, 2014, the trial court ordered the parties back to another conference

on December 23, 2014.

Counsel prepared for and represented his clients in an Adversarial

hearings in Hunt County Child Protection Court for Northeast Texas #2 on

December 3, 2014 in Cause No. 81,304 In the Interest of TH & Z.H., Children, as

well as a Final Hearing in Cause No. 80,139 In the Interest of D.B., a Child in the

196th Judicial District among several others. Counsel prepared for and represented his clients in an Adversarial hearing in

Cause No. 81,304 In the Interest of T.H. &Z.H., Children on December 18, 2014.

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 Willie Frank Jackson CERTIFICATE OF SERVICE

This is to certify that on December 29, 2014, a true and correct copy of the

above and foregoing document was served on the District Attorney's Office, Hunt

County, by electronic filing system.

/s/ Jason A. Duff Jason A. Duff