Court of Civil Appeals of Texas, 2015

Stacy Lee Jones v. State

Stacy Lee Jones v. State
Court of Civil Appeals of Texas · Decided August 13, 2015

Stacy Lee Jones v. State

Opinion

ACCEPTED 14-15-00484-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 8/13/2015 10:25:26 PM CHRISTOPHER PRINE CLERK NO. 14­15­00484­CR STATE OF TEXAS § IN THE FILED IN 14th COURT OF APPEALS § HOUSTON, TEXAS V. § FOURTEENTH COURT 8/13/2015 10:25:26 PM § CHRISTOPHER A. PRINE Clerk STACEY LEE JONES § OF APPEALS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Stacey Lee Jones, 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: 1. This case is on appeal from the 183rd Judicial District Court of Harris County, Texas.

2. The case below was styled the STATE OF TEXAS vs. Stacey Lee Jones, and numbered 1427818.

3. Appellant was convicted of Aggravated Robbery.

4. Appellant was assessed a sentence of 20 years TDCJ­ID on May 15, 2015.

5. Notice of appeal was given on May 15, 2015.

6. The clerk's record was filed on July 10, 2015; the reporter's record was filed on June 30, 2015.

7. The appellate brief is presently due on August 10, 2015.

8. Appellant requests an extension of time of 30 days from the present date, i.e. September 9, 2015.

9. No extension to file the brief has 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 for Appellant is a sole practitioner who must make appearances in county and district court most every work day.

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, JUAN M. CONTRERAS, JR. S. LOCKWOOD HOUSTON, TEXAS 77011 713/287­1209 713/926­0373 FAX

/s/ Juan M. Contreras, Jr. By:___________________________ JUAN M. CONTRERAS, JR. State Bar No. 00787275 Attorney for Stacey Lee Jones

CERTIFICATE OF SERVICE This is to certify that on August 14, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Harris County, 1201 FRANKLIN, HOUSTON, TEXAS 77002, by regular mail.

/s/ Juan M. Contreras, Jr. __________________________________ JUAN M. CONTRERAS, JR.

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