CASEY MICHAEL RHYNES V. THE STATE OF TEXAS MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF Page 1 of 4 CASE NO s . 09

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- CR CASEY MICHAEL RHYNES § IN THE COURT OF APPEALS § v . § 9 th DISTRICT § THE STATE OF TEXAS § BEAUMONT , TEXAS MOTION TO EXTEND TIME TO FILE APPELLANT ’ S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: CASEY MICHAEL RHYNES , Appellant in the above styled and numbered case, 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 359th Judicial District Court of Montgomery County, Texas.
2. The case below was styled The State of Texas vs. Casey Michael Rhynes , and numbered 15

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- CR counts I, II, III, and IV

. 3. Appellant was convicted of the offense s of aggravated assault against a public servant, two counts of aggravated assault with a deadly weapon, and evading arrest or detention with a vehicle

. ACCEPTED 09-17-00440-CR NINTH COURT OF APPEALS BEAUMONT, TEXAS 3/27/2018 8:54 PM CAROL ANNE HARLEY

CLERKCASEY MICHAEL RHYNES V. THE STATE OF TEXAS MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF Page 2 of 4 4. On October 27, 2017 , Appellant was ass essed a sentence of fifty years confinement in the Texas Department of Criminal Justice Institutional Division

. 5. Notice of appeal w as given on November 16 , 2017

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. The C lerk ’s R ecord w as filed on February 26 , 20 1 8 . T he R eporter ’ s R ecord was filed on January 1 4, 2018

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. The appellate brief is presently due on March 28 , 20 18

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. Appellant requests an extension of time of 30 days from the present date, i.e. April 27, 2018

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. No extension s to file the brief ha ve been received in this

cause. 1 0

. Appell ant is currently incarcerated

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. Appellant relies on the following facts as good ca use for the requested extension. Counsel has been preparing for trial in Cause No

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- 322588 , the State of Texas vs. Austin Scott Moore , which

wa s set for trial in the County Court at Law No. 1 of Montgomery County, on April 2 , 201 8 , and w as resolved with

a n agreed plea of guilty on March 2 0, 201 8

.CASEY MICHAEL RHYNES V. THE STATE OF TEXAS MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF Page 3 of 4 Counsel has been preparing for trial in Cause No

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- 324419 , the State of Texas vs. Taylor Ann Sterling, which was set for trial in the County Court at Law No. 1 of Montgomery County, on March 12, 2018, and was resolved in an agreed plea of guilty on the trial date

. Counsel was engaged to apply for a determination of heirship and for letters of administration in the Estate o f Barbara Ann Km iecik, in Cause No. 465569, which was filed in the Probate Court No. 3 of Harris County, on March 23,
2018. CASEY MICHAEL RHYNES PRAYS that the Court grant this Motion t o Extend Time to File Appellant ’ s Brief.

Respectfully submitted, Matt Brown Attorney at Law 3 32 North Main Street Conroe, Texas 77301 832

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- 7538 936

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- 1233 f acsimile matt@pmbrownlaw.com
By:CASEY MICHAEL RHYNES V. THE STATE OF TEXAS MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF Page 4 of 4 Matt Brown State Bar No. 240483 6 7 Attorney for Casey Michael Rhynes

CERTIFICATE OF SERVICE This is to certify that on March 27 , 201 8 , a true and correct copy of the above and foregoing document was served on the Montgomery County District Attorney ’ s Office via the electronic filing manager

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Matt Brown