Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 3/25/2015 3:12:56 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00957-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 3/25/2015 3:12:56 PM CHRISTOPHER PRINE CLERK
NO. 14-14-00957-CR
NO. 14-14-00959-CR
________________________________________
In the
Court of Appeals
For the
Fourteenth District of Texas
At Houston
________________________________________
No. 1424405
No. 1424406
In the 337 th District Court of
Harris County, Texas
________________________________________
GERALINE GREGORY LINCOLN,
Appellant
v.
THE STATE OF TEXAS,
Appellee MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS OF TEXAS:
COMES NOW GERALINE GREGORY LINCOLN, the Appellant in the
above styled and numbered cause, and pursuant to Rules 10.5(b) and 38.6(d) of the
Texas Rules of Appellate Procedure, respectfully moves this Honorable Court to
extend the time to file the Appellant’s brief, and in support thereof would show the
Court as follows:
I.
Undersigned counsel was retained on February 5, 2015.
II.
The deadline for filing the Appellant’s Brief in this case is April 1, 2015.
III.
The Appellant requests a 30-day extension for filing his Brief.
IV.
No other extensions have been requested.
V.
The following facts are relied upon to show good cause for the requested
extension:
a. This case involves a motion to suppress hearing.
b. The appellant was sentenced to eight years in prison.
c. The exhibits have not been filed with this Honorable Court and undersigned
counsel has not yet viewed them. They are crucial to the appeal and the
court reporter is working to supplement the record.
d. The Appellant’s motion is not for purposes of delay, but so justice may be
done by affording effective assistance of counsel.
WHEREFORE PREMISES CONSIDERED, the Appellant respectfully
requests that this Honorable Court grant an extension of time until May 1, 2015 in
which to file the Appellant’s brief in this case.
Respectfully submitted,
_/s/ Megan E. Smith
MEGAN E. SMITH
State Bar No. 24076196
917 Franklin, Suite 310
Houston, Texas 77002
(713) 899-5438
(713) 527-2749 (fax)
megan@megansmithlaw.com
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the Appellant’s Motion for
Extension of Time to File Appellant’s Brief was electronically delivered to Mr.
Alan Curry, Appellate Division Chief, Harris County District Attorney’s Office, on
this 25th day of March 2015.
__/s/ Megan E. Smith____
MEGAN E. SMITH