Case Information
*0 FILED IN 9th COURT OF APPEALS BEAUMONT, TEXAS 12/13/2017 5:05:13 PM CAROL ANNE HARLEY Clerk *1 ACCEPTED 09-17-00060-CR NINTH COURT OF APPEALS BEAUMONT, TEXAS 12/13/2017 5:05 PM CAROL ANNE HARLEY CLERK NO:09-17-00060-CR
TRIAL COURT CASE NO(s) 12519 COURT OF APPEALS
NINTH DISTRICT
BEAUMONT, TEXAS
JOSEPH LEWIS § APPEAL FROM THE 1-A DISTRICT
§ COURT § vs. § OF
§ THE STATE OF TEXAS, APPELLEE § TYLER COUNTY, TEXAS
MOTION TO EXTEND THE TIME
FOR FILING APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
COMES NOW the Appellant and moves the Court for an extension of time to file a
Appellant’s brief in the cause, and in support thereof would show the Court as follows:
I. th
On January 9 , 2009, the Appellant plead Guilty, to the offense of Aggravated Sexual
Assault of a Child. On February 9 , 2017, he was found guilty by jury verdict, and was sentenced th th
on February 9 , 2017, to a Life sentence in the Texas Department of Criminal Justice, under Cause
No. 12,519; THE STATE OF TEXAS VS. JOSEPH CHRISTOPHER LEWIS; IN THE 1-a
DISTRICT COURT OF TYLER COUNTY, TEXAS. THE STATE OF TEXAS VS. JOSEPH
LEWIS; IN THE 1-A DISTRICT COURT OF TYLER, TEXAS.
II.
The Appellant timely filed his Notice of Appeal and the Transcript and Statement of Facts
were timely filed herein, and the Appellant’s Brief was due to be filed herein on December 13 ,
2017. III.
Appellant respectfully requests that this Honorable Court grant an additional extension of
approximately thirty (30) days or until January 12 , 2018, in filing Appellant’s Brief th
IV.
The such extension is necessary for the following reasons:
1. Counsel makes this request for extension because he has been scheduled in multiple
counties on the felony trial dockets in Jefferson, Hardin, Liberty, Newton, and Tyler Counties, for
announcement, pretrial and trial dockets. Counsel has been heavily scheduled on the Hardin County th th
Dockets, in both the 356 and 88 Judicial District Courts. Counsel sincerely apologizes to this
honorable court for filing an additional extension and wishes to remain in good standing with this
Honorable Court, but he prays that the court will grant this second extension to allow the needed
time to finalize and file Appellant’s Brief to ensure accuracy and eliminate the possibility of error.
2. As well, counsel respectfully informs the court he has been working on several other
briefs, (in the Ninth Court of Appeals), writs and petitions for discretionary review, during this time
of which have required more than the usual amount of time in research and reviewing case law.
3. Counsel informs the court this extension is not sought for delay, but that justice may
be done.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests and prays
that this Honorable Court extend the time for the filing of Appellant’s Brief herein approximately
on January 12 , 2018.
Respectfully submitted, /s/ Bryan S. Laine Bryan S. Laine TBN. #24011488 1045 S. Redwood Kountze, Texas 77625 Tel: (409) 246-4008 Fax: (409) 246-3645 bryanlaine@gt.rr.com *3 CERTIFICATE OF SERVICE
I hereby certify that true and correct copy of the foregoing document has been forwarded
to all opposing counsel and parties on this the 13 day of December 2017. By:/s/ Bryan S.Laine /s/Bryan S. Laine State Bar No. 24011488 *4 NO:09-17-00060-CR
TRIAL COURT CASE NO(s) 12,519 COURT OF APPEALS
NINTH DISTRICT
BEAUMONT, TEXAS
JOSEPH LEWIS § APPEAL FROM THE 1-A DISTRICT
§ COURT § vs. § OF
§ THE STATE OF TEXAS, APPELLEE § HARDIN COUNTY, TEXAS
O R D E R On________________________, 2017, came on to be considered JOSEPH LEWIS’S
Appellant’S Motion to Extend the Time For Filing Appellant’s Brief and said motion is hereby:
(Granted) (Denied)
JUDGE PRESIDING