Court of Civil Appeals of Texas, 2015

Bobby Eugene Clark, Jr. v. State

Bobby Eugene Clark, Jr. v. State
Court of Civil Appeals of Texas · Decided October 14, 2015

Bobby Eugene Clark, Jr. v. State

Opinion

BoBBY EUGENE CLARK.';lJR. § App. No. 06-15-00061~c73h FILEDIN APPELLAN ,_ eCour+opr r~ . , k pea!s Th§!`j-_;'._§fg&?,p'§,s § IN THE COURT oF APPEALS S¢xzh D,~St,,-Ct &thBth 0 § FOR THE sISTH DISTRICT ' Uc,i 13 2015 CI 3 3 2015 .. _ § 'TEXARKANA TEXAS n .

Dzr?:;z.;“.-::;Jna, Texas \ - ' De;@)<a';ka¢a, T@Xas <=»‘ ?a Autrc-:y Cierk . F<'=¥""?».Am~e»...© ' THE STATEA§;E§§§;S ’ § oN APPEAL FRoM cAUsE No.42863-B l “y LEM< ' § GREGG coUNTY,TEXAS

HONORABLE ALFONSO CHARLES, PRESIDING JUDGE

FIRST MOTION FOR EXTENSION OF TIME IN WHICH TO FILE A RESPONSE TO ADNERS BRIEF

NOW COMES, BOBBY EUGENE CLARK,JR.,APPELLANT,prOCeeding pro Se and hinformapauperis,in the above style and number cause to present his First Motion forrExtension of Time inwhich to file a Response to Anders Brief. Appellant request that the extension be for (90) days. Appellants request for extension of time is not for purposes `of delay/but,that he may fairly have enough time to properly prepare his response. , v On August 19,2015 appointed appeal attorney/Jonathan Wharton, filed appellants Anders Brief,with this Court. On September 15, 2015 the Court Granted appellants pro se motion to access to a appellate record and requested counsel to foward a copy of the record to appellant. On Septmber the 17th appellant received the appellate record,by Rule appellant has (30) days to file a response

MOTION FOR EXTENSION OF TIME pq. l the response is due on October l7/2015,however being that falls on a saturday/the date for filling would be moved to October 191 2015.In support of this motion appellant shows the following: A). On September lO,ZOlB the Michaels Unit was placed on a scheduled lockdown and did not come up untile September 25,2015.

B). The Unit had absolutely no movement;therefore,the appellant has been unable to go to the law library toédo his research.

C). Appellant is trying to gain counsel/through his family,to represent hin in this matter.

This is appellants First request for an extension of time in this case.Appellant assures the Court that this request is not designed to harass/nor unnecessarily delay the proceeding,but/ to ensure that appellant has sufficient time to l) gain counsel or 2) fully respond to the Ander Brief. Appellant Respectfully Moves This Court for an extension of (90) days to file a response.

PRAYER Appellant,prays that in all things/this Motion be Granted.

UNSWORN DECLARATION`OF INMATE

I,BOBBY EUGENE CLARK/JR.,TDCJ # 1997376,Currently incarcerated in the Texas Department of Criminal Justice at the Michael Unit in Tennessee Colony Texas,do solemnly sweareunder the penalties of perjury that the foregoing Motion is true and correct to the best of my knowledge. l further state the enclosed information is true and correct.' /E(:%?/%/L EXECUTED ON OCTOBER 9th 2015.

Bobby Eugene Clark,Jr-l997376 Michael Unit 2664 FM 2054 Tennessee Colony/Tx.75886 APPELLANT pro se

MOTION FOR EXTENSION OF TIME page 2

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