Case Information
*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 3/20/2015 2:24:35 PM DEBBIE AUTREY Clerk *1 ACCEPTED 06-14-00207-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 3/20/2015 2:24:35 PM DEBBIE AUTREY CLERK NO. 06-14-00207-CR _____________________________________________________________
IN THE COURT OF APPEALS FOR THE SIXTH APPELLATE DISTRICT OF TEXAS AT TEXARKANA _____________________________________________________________
KARL PATRICK HOULDITCH vs.
THE STATE OF TEXAS _____________________________________________________________
Appealed from the 71 st District Court of Harrison County, Texas Trial Cause No. 13-0263X _____________________________________________________________
APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE JUSTICES OF THE SIXTH COURT OF APPEALS:
COMES NOW KARL PATRICK HOULDITCH, APPELLANT, on appeal
in Cause No. 13-0263X, and files this, his First Motion for extension of
Time to File Appellate Brief, and pursuant to Rule 10.5(b), TEX. R. APP.
PROC., and pursuant to the extension policies of this Court, makes this
request to extend filing the brief in this cause and would show as follows:
I. The Official Court Reporter has filed the Reporter’s record with this Honorable Court. The undersigned has received copies of that record as well
as the Clerk’s Record. The deadline for filing Appellant’s Brief is on or before
March 25, 2015.
II.
Appellant requests an additional thirty (30) days in which to complete the
research and writing necessary for submission of the brief.
III.
As reasonable explanation for the need for an extension of time Appellant
would show as follows:
While counsel for Appellant has devoted time to reading the record,
research, and drafting the Brief, the Brief is not yet finished. Moreover, the record
is not yet complete, since there is an important exhibit missing, namely, State’s
Exhibit No. 1 from the hearing on the Motion to Suppress. Counsel has
communicated with the Court Reporter and District Clerk about this problem, and
reasonably expects that the Exhibit will be found and supplied, along with a
Supplemental Clerk’s Record of additional documents in the appeal. However, as
of this date, those matters are not yet resolved.
Appellate counsel has also during the past thirty days devoted his time to
other matters in his office, including, but not limited to, the following matters:
Work on Criminal Appeals
Continued correspondence with Appellant and preparation for oral argument
in Esaw Lampkin v. State, Appellate Cause No. 06-14-00024-CR.
Drafting and filing the Brief for Appellant in Cinque Ross vs. the State of
Texas, Appellate Cause No. 06-14-00157-CR.
Correspondence with client in Tommy Scott Thomas, Cause No. PD-0057-
15, Petition for Discretionary Review
Probate & Estate Work
Cause No. 2015-0031-E In re Estate of Hall: work on inventory and
correspondence with heirs
Cause No. 2013-0284-P, In re Estate of Bedsole: work on final accounting;
correspondence with client
Work on Civil Appeal
Correspondence with client in Cause No. 06-14-00087-CV, In the Interest of J.
M. A. E. W., A Child
Child Protective Services Work
CPS conferences, court hearings, correspondence in the following cases:
No. 2015-369-CR, “Interest of D.W. and K.W.”
No. 2015-178-DR, “Interest of X.D.T.”
No. 2013-983-DR, “Interest of K.S., A.C., R.L.C., and R.D.C.”
No. 2014-180-DR, “Interest of K.M. & K.J.”
No. 2014-1405-DR, “Interest of A.R. and F.L.R.”
No. 2014-1596-DR, “Interest of J. S., S. H., AND R. H.”
No. 2014-1776-DR, “Interest of D. N.”
Civil Litigation
Drafting motions, getting settings, correspondence, and/or other activities in
following:
Cause No. 2014-2434-CCL2, Pope & Turner, Inc., of Overton vs. John
Edward McDade, Jr., et al, pending in County Court at Law No. 2, Gregg County
Cause No. CV14-1856, Sacor Financial, Inc., etc. vs. Texas Bank & Trust,
pending in 43 rd District Court of Parker County, action in garnishment
Cause No. S1-122-14, Pegues-Hurst vs. David Williams, Inc; preparation for
trial and obtaining default judgment
Cause No. 2014-2257-B, Texas Bank & Trust vs. Johnson, working on
agreement to conclude litigation
Counsel has also spent several hours in conference during each week of the
past 30- day period with clients who have consulted with counsel on such diverse
areas of law as collections, criminal law, probate, juvenile, and other legal matters.
With a grant of an additional thirty days Appellate counsel plans to finish writing the brief and submit it to the Court, provided the missing exhibit is
supplied and the Supplemental Clerk’s Record is filed.
IV.
There has previously been no motion filed for extension of time, or grants of
time extended to Appellant, for the filing of Appellant's brief.
WHEREFORE, PREMISES CONSIDERED, KARL HOULDITCH,
Appellant, respectfully requests that this Honorable Court of Appeals will, upon
reviewing this Motion, grant the extension of time for filing Appellant's brief as
requested herein, and for such other relief to which Appellant may be entitled.
Respectfully submitted, LAW OFFICES OF LEW DUNN _/s/ Lew Dunn_ Lew Dunn Attorney at Law 201 E. Methvin, Suite 102 P.O. Box 2226 Longview, Texas 75606 903-757-6711 FAX 903-757-6712 Texas State Bar No. 06244600 ATTORNEY FOR APPELLANT *6 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing Motion
was hand-delivered or sent by first class mail or by electronic transmission to
the office of Hon. Tim Cariker, Assistant Criminal District Attorney, Harrison
County Courthouse, 200 W. Houston Street, Suite 206, Marshall, Texas 75670 on
this 20 day of March, 2015.
/s/_LewDunn__ ___________ Lew Dunn COUNSEL FOR APPELLANT