*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 3/13/2015 10:36:30 AM DEBBIE AUTREY Clerk *1 ACCEPTED 06-14-00192-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 3/13/2015 10:36:30 AM DEBBIE AUTREY CLERK IN THE COURT OF APPEALS Sixth Appellate District State of Texas REGINALD REECE,
Appellant
v. NO. 06-14-00192-CR
Trial Court #11F0746-202 STATE OF TEXAS,
Appellee
MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW Reginald Reece , Appellant, by and through his below
named Attorney and pursuant to Texas Rules of Appellate Procedure, hereby
requests an extension of the time period for the filing of the Appellant’s Brief
and in support of same would show the Court as follows:
A. This case is pending from the 20nd Judicial District Court of Bowie
County, Texas. The date of the Judgment is October 12, 2014, with
sentence being imposed by the trial court on October 12, 2014.
B. The case was styled, “State of Texas v. Reginald Reece, Cause No. 11 F
0746 202.
C. Appellant was convicted of the offense of Theft of less than $1500.00,
With Prior Convictions.
D. Punishment was assessed by the jury to 20 years in the Institutional
Division of the Texas Department of Criminal Justice.
E. The Appellant’s Brief is due to be filed March 16, 2015.
F. Appellant requests an extension of the filing of Appellant’s Brief Forty-
Five (45) days, making the Appellant’s Brief due on April 30, 2015.
G. Appellant’s attorney has been diligent in researching and preparing the
Appellant’s brief for the Court however, due to counsel’s preparation in
a capital murder criminal jury trial styled the State of Arkansas v. Tim
Howard, in the Circuit Court of Little River County, Arkansas, counsel
has had insufficient time to complete Appellant’s brief.
H. There have been no previous requests for extensions in this cause. Counsel for Appellant has contacted the Assistant Criminal District
Attorney for Bowie County, Texas, who is assigned to this matter and
she has no objection to the request of the Appellant.
II.
Appellant’s attorney has been diligent in pursuing this appeal and is not
seeking this extension for the purpose of delay.
PRAYER
WHEREFORE, on the basis of the Texas Rules of Appellate Procedure,
Appellant’s attorney respectfully requests this Court to grant the Motion for
Extension of Time for the filing of Appellant’s Brief.
Respectfully submitted, /s/ Alwin A. Smith Alwin A. Smith TBN: 18532200 al@alwinsmith.com 602 Pine Street Texarkana, Texas 75501 903/792-1608 903/792-0899 Fax CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing
Motion for Extension of Time to File Appellant’s Brief has been forwarded to
Michael Shepherd, 601 Main Street, Texarkana, Texas, on this the _13th_ day
of March 2015.
/s/ Aliwn A. Smith Alwin A. Smith