Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 2/11/2015 12:19:18 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-14-00895-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 2/11/2015 12:19:18 PM CHRISTOPHER PRINE CLERK
No. 01-14-00895-CR
In the First Court of Appeals, Houston, Texas
LAMAR MARCELL HUNTER Appellant
v. THE STATE OF TEXAS Appellee
Appellant’s Second Motion for Extension of Time to File Brief Respectfully Submitted by:
Joseph Kyle Verret
THE LAW OFFICE OF KYLE VERRET, PLLC
Counsel for Appellant
TBN: 240429432
11200 Broadway, Suite 2743
Pearland, Texas 77584
Phone: 281-764-7071
Fax: 281-764-7071 Submitted:
Email: kyle@verretlaw.com February 11, 2015
*2 No. 01-14-00895-CR
In the First Court of Appeals, Houston, Texas
LAMAR MARCELL HUNTER Appellant
v. THE STATE OF TEXAS Appellee
Appellant’s Second Motion for Extension of Time to File Brief
Comes now, Appellant, by and through his undersigned counsel, in the above
styled cause and moves this Honorable Court to extend the time for the filing
of Appellant's Brief. Per Texas Rule of Appellate Procedure 10.5(b),
Appellant provides the following:
Current Deadline for Filing: February 11, 2015
Length of Extension Sought: Thirty (30) Days
Number of Previous Extensions Granted: One.
Basis for Extensions:
Appellant's counsel is a solo practitioner with a busy criminal and juvenile defense caseload, which requires regular appearances in court on the
part of counsel.
An agreed motion to abate this is appeal to the trial court to correct the *3 trial court’s certificate of right of appeal.
Also, in the thirty days since the last motion for extension in this matter, counsel prepared and filed a brief in Appeal No. 14-14-00585-CR, 14-14-
00586-CR, and 14-14-00587-CR in the Fourteenth Court of Appeals. This
brief was filed on Friday, January 6, 2015.
Also, Appellant’s counsel prepared for an Aggravated Assault with a Deadly Weapon trial in Cause 74051 in Brazoria County, Texas that was set
for trial on January 26, 2015. While the case was resolved prior to trial,
counsel spent significant time preparing for this trial.
Counsel for Appellant seeks this extension of time to be able to prepare a cogent and succinct brief to aid this Court in its analysis of the issues
presented. This request is not sought for delay but so that justice may be done.
All facts recited in this motion are within the personal knowledge of the counsel signing this motion, therefore no verification is necessary under Rule
of Appellate Procedure 10.2.
PRAYER FOR RELIEF For the reasons set forth above, Appellant requests that this Court grant this Appellant’s Second Motion to Extend Time to File Appellant’s Brief and
extend the Deadline for Filing the Appellant’s Brief up to and including March
13, 2015. Appellant prays all other relief to which he may be entitled.
Respectfully submitted,
/s/ Joseph Kyle Verret
Joseph Kyle Verret
THE LAW OFFICE OF KYLE VERRET, PLLC
Counsel for Appellant
TBN: 240429432
11200 Broadway, Suite 2743
Pearland, Texas 77584
Phone / Fax: 281-764-7071
Email: kyle@verretlaw.com
Certificate of Service
I certify that a true and correct copy of the foregoing Appellant's Second Motion for Extension of Time to File Brief was served on this 11th day of
February, 2015 on the Counsel for the Appellee, Rebecca Klaren, at the
Galveston County Criminal District Attorney’s Office by e-service through
electronic filing.
/s/ Joseph Kyle Verret
Joseph Kyle Verret
TBN: 2402932