Case Information

*0 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 9/14/2015 1:35:27 PM PAM ESTES Clerk *1 ACCEPTED 12-15-00157-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 9/14/2015 1:35:27 PM Pam Estes CLERK NO. 12-15-00157-CR

ON APPEAL FROM THE 159 TH JUDICIAL DISTRICT COURT

ANGELINA COUNTY, TEXAS

CAUSE NO. 2013-0744 IN THE 12 TH COURT OF APPEALS

STANFORD JONES, JR. §

§

§ OF

vs. §

§

STATE OF TEXAS § TYLER, TEXAS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Stanford Jones, Sr., Appellant in the above styled and numbered

cause, and moves this Court to grant an extension of time to file appellant's brief,

pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good

cause shows the following: This case is on appeal from the 217 District Court of Angelina

1.

County, Texas.

2. The case below was styled the STATE OF TEXAS vs. Stanford Jones,

Sr., and numbered 2013-0744. Appellant was convicted of Arson.

4. Appellant was assessed a sentence of Twenty (20) years in Texas

Department of Criminal Justice Institutional Division on May 14, 2015.

5. Notice of appeal was given on June 10, 2015.

6. The clerk's record was filed on July 10, 2015; the reporter's record was

filed on June 29, 2015.

7. The appellate brief was presently due on September 11, 2015.

8. Appellant requests an extension of time of thirty (30) days from the

current due date.

9. One extension to file the brief have been received in this cause.

10. Defendant is currently incarcerated.

11. Appellant relies on the following facts as good cause for the requested

extension:

Counsel was recently out for over a week due to an infection and was

subsequently diagnosed with insulin dependent diabetes. Counsel has been

physically unable to return to work on a full time basis and would like additional

time to complete the brief.

WHEREFORE, PREMISES CONSIDERED , Appellant prays that this

Court grant this Motion to Extend Time to File Appellant's Brief, and for such other

and further relief as the Court may deem appropriate.

Respectfully submitted: ____________________ Attorney at Law

1007 Grant

Lufkin, Texas 75901 Phone (936) 632-160 Fax: (936) 632-1640 tessabellus@yahoo.com SBOT # 16723000 Counsel for Appellant *3 CERTIFICATE OF CONFERENCE

Pursuant to Tex. R. App. 10.1 (5), certify that I, the undersigned conferred

with opposing counsel who is not opposed to an extension.

/s/John D. Reeves

___________________________

John D. Reeves

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Appellant’s

Motion to Extend Time to file Appellant’s Brief on this 14 day of September,

2015 forwarded to State’s Attorney, April Ayers-Perez, Angelina County, by

electronic service at aprerez@angelinacounty.net.

__________________________

Attorney for Appellant,

Stanford Jones, Sr.