Yago Santain Fountain v. State

Opinion

ACCEPTED 12-15-00073-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 7/15/2015 9:47:25 PM CATHY LUSK CLERK

No. 12-15-00073-CR

YAGO FOUNTAIN § IN THE COURT OF APPEALS FILED IN Appellant § 12th COURT OF APPEALS TYLER, TEXAS § vs. § 12TH JUDICIAL 7/15/2015 DISTRICT 9:47:25 PM CATHY S. LUSK § Clerk THE STATE OF TEXAS, § Appellee § AT TYLER, TEXAS

APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF -- THREE DAY REQUEST

TO THE HONORABLE COURT:

Now comes Austin Reeve Jackson, counsel for Appellant in the above entitled and

numbered cause, and makes this Motion, and for good cause shows the following:

I.

Appellant’s brief in this matter is due on 15 July 2015. One prior extension has

been requested.

II.

While working on this case counsel has also been working on approximately 55

open appellate cases in this and other courts to which he has been appointed by Smith

County. This has included investigating motions for new trials (looking for and talking

with potential witnesses, jail and office visits with new appellate appointments, trial court

appearances for the same), requests for and reviews of reporter’s and clerk’s records,

research, briefing, review of opinions, investigation of potential PDR issues, etc. While

not all of these cases have required significant attention from counsel during this time, many of them have which has resulted in counsel having been unable to devote the full

attention necessary to this case prior to today’s date.

One prior extension has been requested and it is respectfully prayed that the in the

interest of justice, the Court grant this motion.

WHEREFORE, PREMISES CONSIDERED, undersigned counsel respectfully

prays that, in accordance with the applicable law, the Court grant this Motion and extend

the date by which to file a brief by three days.

Respectfully submitted,

/s/Austin Reeve Jackson Texas Bar No. 24046139 112 East Line, Suite 310 Tyler, TX 75702 Telephone: (903) 595-6070 Facsimile: (866) 387-0152

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing document

was served on counsel for the State by efile concurrently with its filing.

/s/Austin Reeve Jackson