ACCEPTED

06-16-00032-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

9/12/2016 12:00:00 AM

DEBBIE AUTREY

CLERK

NO. 06-16-00032-CR

FILED IN

6th COURT OF APPEALS STATE OF TEXAS § IN THE COURT TEXARKANA, TEXAS

§ 9/12/2016 7:50:00 AM vs. § OF APPEALS DEBBIE AUTREY

§ Clerk JAMEL MCLELLAND FOWLER § SIXTH APPELATE DISTRICT

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Jamel McLelland Fowler, Appellee in the above styled and numbered cause, and moves this Court to grant and extension of time to file Appellee’s brief pursuant to Rule 38.6 of the Texas Rules of Appellant Procedure and for good cause shows the following:

1. This case is on appeal from the 196th District Court, Hunt County, Texas;

2. The case below was styled State of Texas vs. Jamel McLelland Fowler,

Cause Number 30,511.

3. Appellee was not convicted.

4. Appellee was not sentenced.

5. Notice of Appeal was given on February 26, 2016.

6. The Clerk's record was filed on June 15, 2016; The Reporter's record was

filed on June 20, 2016.

7. Appellee's brief is currently due on September 12, 2016.

8. Appellee requests an extension of time of 30 days from the current due date.

9. No extension has been previously requested in this cause number.

10. Appellee is not incarcerated in this cause number.

11. Appellee relies on the following facts as good cause for the extension

requested:

Appellee's attorney, Jessica Edwards, is a sole practitioner. In the last 35 days Counsel has had multiple unexpected hearings, filed three briefs including 06-16-00038-CR (Appellee’s appellant brief), 06-16-00121-CR, and 06-16-00100-CR, and drafted a Writ of Mandamus to be submitted in the Twelfth Court of Appeals. Counsel is also preparing for oral arguments in 06-16-00179-CR to be heard on September 28, 2016. Counsel has had insufficient time to adequately examine the record in order to effectively prepare a brief in this case.

WHEREFORE, PREMISIS CONSIDERED, Appellant prays that this Court would grant Appellant's Motion to Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate.

Respectfully submitted,

_/s/Jessica Edwards______

Jessica Edwards

SBN: 24000994

P.O. Box 9318

Greenville, Texas 75404

Tel: (903) 458-9108

Fax: (903) 200-1359

E-Mail: [email protected]

Attorney for Jamel McLelland Fowler

CERTIFICATE OF SERVICE

This is to certify that on September 10, 2016, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, by email.

/s/Jessica Edwards

Jessica Edwards