ACCEPTED

06-15-00168-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

12/16/2015 3:34:25 PM

DEBBIE AUTREY

CLERK

NO. 06-15-00168-CR

IN THE COURT OF APPEALS FILED IN

6th COURT OF APPEALS

FOR THE SIXTH APPELLATE DISTRICT TEXARKANA, TEXAS

AT TEXARKANA 12/16/2015 3:34:25 PM

DEBBIE AUTREY

Clerk

LEON HILL

VS.

THE STATE OF TEXAS

APPEALED FROM THE 4TH DISTRICT COURT, RUSK COUNTY, TEXAS

TRIAL CAUSE NO. CR 14-313

FIRST MOTION FOR EXTENSION OF TIME

TO FILE BRIEF FOR LEON HILL, APPELLANT TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW LEON HILL, and pursuant to Rule 10.5(b), TEX. R. APP. PROC., and pursuant to the extension policies of this Court, makes this request to extend filing the brief in this cause and would show as follows:

I.

The Official Court Reporter has filed the Reporter’s record with

this Honorable Court. The undersigned has received copies of

that record as well as the Clerk’s Record. The deadline for filing

1 Appellant’s Brief is on or before December 21, 2015.

II.

Appellant requests an additional thirty (30) days in which to complete the research and writing necessary for submission of the brief.

III.

As reasonable explanation for the need for an extension of time Appellant would show as follows:

While counsel for Appellant has devoted time to reading the record, research, and drafting the Brief, the Brief is not yet finished.

Appellate counsel has also during the past thirty days devoted his time to other matters in his office, including, but not limited to, the following matters:

Work on Criminal Appeals

Working on briefs in these cases:

Casey Jones v. State, No. 06-15-00113-CR

Brendan X. Douglas v. State, No. 06-15-00067-CR

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Preparing and Filing a Petition for Discretionary Review in this case:

Derek Clinton Ward v. State, PD-1573-15

Work on Civil Appeals

Preparing and filing a Petition for Review in:

In the Interest of D.G., K. G., H. M. G., Children, on behalf of

Bennie G., Supreme Court of Texas Docket No. 15-0919

Perfecting Appeal in “In the Interest of K.O, A.O. and O.O.”

Cause No. 06-15-00100-CV. Probate & Estate Work (All in Gregg County)

Cause No. 2014-0317-P In re Estate of Baker: conference with counsel

Cause No. 2015-0297-E In re Estate of Roberts: conference with counsel

Cause No. 2015-0352-E, In re Guardianship of Tommie Johnson: interview ward, prepare pleadings and report, attend hearing on temporary guardianship

Child Protective Services Work (All in Gregg County)

CPS conferences, court hearings, correspondence in the following cases:

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No. 2015-1190-CCL2, “Interest of G. O.”

No. 2015-369-DR, “Interest of D. W. and K. W.”

No. 2015-2162-DR, “Interest of C. Z. Y.”

No. 2015-1171-CCL2, “Interest of C.F.”

No. 2013-955-DR, “Interest of A. T.”

No. 2014-2343-DR, “Interest of J. L. B.”

No. 2014-873-DR, “Interest of J. K. V.”

No. 2014-873-DR-1, “Interest of K. V.”

Counsel has also spent several hours in conference during each week of the past 30-day period with clients who have consulted with counsel on such diverse areas of law as collections, criminal law, probate, juvenile, and other legal matters.

With a grant of an additional thirty days Appellate counsel plans to make substantial progress in further reading of the record and in the writing and research on the brief.

IV.

There has previously been no motion filed for extension of time, or grants of time extended to Appellant, for the filing of

4 Appellant's brief.

WHEREFORE, PREMISES CONSIDERED, LEON HILL, Appellant, respectfully requests that this Honorable Court of Appeals will, upon reviewing this Motion, grant the extension of time for filing Appellant's brief as requested herein, and for such other relief to which Appellant may be entitled.

Respectfully submitted,

LAW OFFICES OF LEW DUNN

_/s/ Lew Dunn_

Lew Dunn Attorney at Law

201 E. Methvin, Suite 102

P.O. Box 2226

Longview, Texas 75606

TEL. 903-757-6711

FAX 903-757-6712

Texas State Bar No. 06244600

ATTORNEY FOR APPELLANT

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing “First Motion for Extension of Time to File Brief for Leon Hill, Appellant” has been sent by electronic transmission to the following on this 16th day of December, 2015:

Hon. Zack Wavrusa, Assistant Criminal District Attorney, Rusk County, Texas, at his e-mail address: [email protected].

__/S/ Hough-Lewis Dunn

Hough-Lewis (“Lew”) Dunn

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