Case Information

*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 12/22/2015 10:29:56 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-15-00589-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 12/22/2015 10:29:56 PM CHRISTOPHER PRINE CLERK NO. 14-15-00589-CR IN THE COURT OF APPEALS FOR THE FOURTEENTH DISTRICT OF TEXAS AT HOUSTON -----------------------------------------------------------------

NO. 13CR1806 IN THE 212 th DISTRICT COURT OF GALVESTON COUNTY, TEXAS -----------------------------------------------------------------

ROYCE GENE ADAMS, III, APPELLANT

V.

THE STATE OF TEXAS, APPELLEE

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MOTION FOR FOURTH EXTENSION OF TIME TO FILE BRIEF OF APPELLANT -----------------------------------------------------------------

Winston E. Cochran, Jr. Attorney at Law Texas Bar No. 04457300 P.O. Box 2945 League City, TX 77574 Tel. (713) 228-0264 E-mail:winstoncochran@comcast.net Counsel for Appellant *2 TO THE HONORABLE COURT OF APPEALS:

COMES NOW the appellant, Royce Gene Adams, III (hereinafter “Adams”),

through the undersigned counsel, and respectfully requests that this Court grant a

fourth, short extension of the time to file the appellant’s brief, until December 31,

2015, for reasons set forth as follows.

1. Adams was indicted for two counts of Aggravated Sexual Assault,

allegedly committed against a child. A jury found Adams guilty as charged on each

count. Punishment was assessed at confinement for forty-five years in the Texas

Department of Criminal Justice, Correctional Institutions Division, plus a fine, on

Count One. Punishment was assessed at confinement for life, plus a fine, on Count

Two.

2. Adams gave timely notice of appeal on both counts. Adams also is

appealing convictions on two counts in another case, as addressed in a separate

motion for extension.

3. The appellant’s brief is due on December 22, 2015, pursuant to a third

extension of time to file the brief. The appellant requests a short, fourth extension.

4. The reasons for the requested extension are as follows:

A. The undersigned counsel has decided to scale down the brief by

abandoning certain issues relating to the guilt stage of trial. Counsel

came to this conclusion very late in the process, and with some

trepidation, but not everything that was questionable at trial makes a

good appellate point. The key issue now will concern a

punishment-stage jury charge request and will apply to all of the counts

at issue in both cases. Counsel simply has not time, by the present due

date, to make the needed structural revisions and to beef up the

argument of the charge issue to counsel’s satisfaction.

B. Unfortunately access to resources will be limited from mid-day on

December 23 through December 27 because of the Christmas holiday

period. Accordingly, counsel believes some time in the week following

Christmas is needed.

Wherefore Adams prays that the time for filing the appellant’s brief in this

cause be extended to December 31, 2015.

Respectfully submitted, /s/ Winston E. Cochran, Jr. Winston E. Cochran, Jr. Attorney at Law Texas Bar No. 04457300 P.O. Box 2945 League City, TX 77574 Tel. (713) 228-0264 E-mail:winstoncochran@comcast.net Counsel for Appellant 3 *4 CERTIFICATE OF SERVICE I certify that a copy of this motion for extension will be served on counsel for

the State at the following address on December 23, 2015:

Galveston County District Attorney’s Office

Appellate Division

600 59 th Street

Galveston, TX 77551

/s/ Winston E. Cochran, Jr. Winston E. Cochran, Jr. 4