Case Information

*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 4/29/2015 10:12:19 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-14-00957-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 4/29/2015 10:12:19 AM CHRISTOPHER PRINE CLERK NO. 14-14-00957-CR NO. 14-14-00959-CR ________________________________________

In the Court of Appeals For the Fourteenth District of Texas At Houston ________________________________________

No. 1424405 No. 1424406 In the 337 District Court of Harris County, Texas ________________________________________

GERALINE GREGORY LINCOLN, Appellant v.

THE STATE OF TEXAS, Appellee SECOND MOTION FOR EXTENSION OF TIME TO

FILE APPELLANT’S BRIEF

TO THE HONORABLE COURT OF APPEALS OF TEXAS:

COMES NOW GERALINE GREGORY LINCOLN, the Appellant in the

above styled and numbered cause, and pursuant to Rules 10.5(b) and 38.6(d) of the

Texas Rules of Appellate Procedure, respectfully moves this Honorable Court to

extend the time to file the Appellant’s brief, and in support thereof would show the

Court as follows:

I.

Undersigned counsel was retained on February 5, 2015.

II.

The deadline for filing the Appellant’s Brief in this case is May 1, 2015.

III.

The Appellant requests a 45-day extension for filing his Brief.

IV.

One 30-day extension was previously granted.

V.

The following facts are relied upon to show good cause for the requested

extension: This case involves a dispositive motion to suppress hearing. The appellant was sentenced to eight years in prison.

c. The exhibits were filed on April 20, 2015 and they are crucial to the appeal.

This week has been undersigned counsel’s first opportunity to view the

exhibits.

d. The reporter’s record was also filed and amended on April 17 and 21 st

respectively.

e. Undersigned counsel is working on an appellate brief that is due in the Fifth

Circuit Court of Appeals on Monday, May 4 and is preparing for a trial

during the week of May 11 in Harris County Criminal Court at Law

Number Ten. Rodney Hood v. William Stephens. Cause No. 14-20779. 5 Cir. State v. Malik Mott. Cause No. 1945406. CCCL 10.

f. The Appellant’s motion is not for purposes of delay, but so justice may be

done by affording effective assistance of counsel.

WHEREFORE PREMISES CONSIDERED, the Appellant respectfully

requests that this Honorable Court grant an extension of time until June 15, 2015 in

which to file the Appellant’s brief in this case.

Respectfully submitted _/s/ Megan E. Smith MEGAN E. SMITH State Bar No. 24076196 917 Franklin, Suite 310 Houston, Texas 77002 (713) 899-5438 (713) 527-2749 (fax) megan@megansmithlaw.com CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Appellant’s Second

Motion for Extension of Time to File Appellant’s Brief was electronically

delivered to Mr. Alan Curry, Appellate Division Chief, Harris County District

Attorney’s Office, on this 29th day of April 2015.

__/s/ Megan E. Smith____ MEGAN E. SMITH