Case Information
*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 12/14/2015 12:20:45 PM DEBBIE AUTREY Clerk
*1 ACCEPTED 06-15-00119-cr SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/14/2015 12:20:45 PM DEBBIE AUTREY CLERK NO. 06-15-00119-CR IN THE SIXTH COURT OF APPEALS OF TEXAS TEXARKANA, TEXAS Carlton Daniel Jones, APPELLANT THE STATE OF TEXAS, APPELLEE On appeal from the 196'" Judicial District Court Of Hunt County, Texas Trial Court Cause No. 30, 042 APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF *2 IN THK COURT OF APPEALS CARLTON DANIEL JONES 6TH SUPREME JUDICIAL DISTRICT TEXARKANA, TEXAS STATE OF TEXAS
TO
THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
NO%' COMES CARLTON DANIEL JONES, in the above styled and the Appellant numbered cause, and would respectfully request an extension of time for filing the Appellee's to Rule 10. 5 and Rule 38 of the Texas Rules of Appellate Procedure, brief in said case pursuant and would respectfully show the following:
Appellee's brief is due to be filed on or before the 14th day of December 2015, Appellee respectfully requests this Honorable Court to grant an extension of time to file
the Appellant's Brief for additional thirty (30) days time from this date to complete and file his Opening, or until the 14'" day of January 2016. In connection therewith, Appellant would show the following facts relied upon in good faith to show good cause to the Honorable Court of Appeals regarding this motion for extension of time:
Counsel for Appellant became aware of the record in this case and has made diligent efforts to review the record and prepare a thorough Opening Brief. Appellant anticipates that one of the issues for review will concern the sufficiency of the evidence. The record includes
taken from the Hunt County jail and the review of these exhibits containing recordings conversations has required some effort to obtain recorded copies of the DVD exhibits that are audible. Appellant has now completed a review of the record and expects to complete the *3 Opening Brief within a few days of the original due date. Counsel for Appellee does not oppose this Motion.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests and prays that the Honorable Court of Appeals grant an extension of thirty (30) days or until January14, 2015 in which the Appellant may complete and file his brief,
Respectfully submitted, Peter I. Morgan Counsel For Appellant State Bar No 14451700 P. O. Box 984 Greenville, Texas 75403 pmorgan@lawyermorgan. corn (903) 217-3671 (903) 642-0057 (fax)
CERTIFICATE
OF SERVICE I hereby certify that a true and correct copy of the above and foregoing instrument was forwarded to all parties by hand delivery or regular mail. Peter I, Morgan *4 VERIFICATION STATE OF TEXAS COUNTY OF HUNT
BEFORE ME, the undersigned Notary Public, on this day personally appeared PETER I. MORGAN, who being by me duly sworn on his oath deposed and said that he is duly qualified and authorized in all respects to make this affidavit; that he has read the above and foregoing Motion for Extension of Time for Filing Brief; and that every
's nowledge and true and correct. statement contained in the Motion is within eter I. Morgan day of December SUBSCRIBED AND SWORN TO BEFORE ME on the 2015, to certify which witness my hand and official seal. +, w. ". 'c'~, Notary Public, State of Texas
REBECCA BLEVlNS 'p~ Notary Public, State of Texas . ~. :. ~:;»! My Commlssiorr Expires