Samson Moses Billiot AKA Samson M Billiot v. State

ACCEPTED 02-17-00139-CR

SECOND COURT OF APPEALS

FORT WORTH, TEXAS 12/20/2017 1:36 PM

DEBRA SPISAK

CLERK IN THE COURT OF APPEALS

FOR THE SECOND COURT OF APPEALS

DISTRICT OF TEXAS FILED IN

2nd COURT OF APPEALS FORT WORTH, TEXAS

SAMSON MOSES BILLIOT § 12/20/2017 1:36:22 PM

§ DEBRA SPISAK

Clerk V. § No. 02-17-00139-CR

§

STATE OF TEXAS §

APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE

BRIEF TO THE HONORABLE COURT OF APPEALS:

COMES NOW, Samson Moses Billiot, Appellant, by and through his attorney of record, and moves this Court to allow him a thirty-day extension, until January 15, 2018, in which to file his brief on appeal. The following allegations are made in support of this motion.

I.

The court below is the 372nd District Court of Tarrant County. The style and number of the case is State v. Billiot, cause number 1474072D.

II.

Appellant was convicted of arson (with intent to destroy a habitation) (deadly weapon, habitual count found true) and sentenced to forty years in prison. Appellant is incarcerated.

III.

Appellant’s brief is due December 22, 2017. This is Appellant’s second request for an extension of time. The date of submission has not yet been set.

IV.

This extension is not requested for purposes of delay. During the previous month, the undersigned attorney has been engaged in drafting the brief in State v. Butler, cause number 1445189D which is due December 20, 2017.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court grant this request and allow for a sixty-day extension until January 15, 2018, for the filing of Appellant’s brief.

Respectfully submitted, /s/ Shelly K. Messerli Shelly K. Messerli State Bar No. 24051044 Attorney for Appellant 505 Pecan Street, Ste. 201 Fort Worth, Texas 76102 817-632-6364 Fax: 817-877-3666 [email protected]

CERTIFICATE OF CONFERENCE

The State does not object to the grant of this extension request.

/s/Shelly K. Messerli Shelly K. Messerli

CERTIFICATE OF SERVICE

A copy of this motion has been sent via electronic mail to the attorney for the State on December 20, 2017.

/s/Shelly K. Messerli Shelly K. Messerli