CASEY MICHAEL RHYNES V. THE STATE OF TEXAS

MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

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CASE NOs. 09-17-00440-CR,

09-17-00441-CR, 09-17-00442-CR, 09-17-00443-CR

CASEY MICHAEL RHYNES § IN THE COURT OF APPEALS

§

v. § 9th 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 15-05-05331-CR counts I, II, III, and 

IV.

3. Appellant was convicted of the offenses 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

CLERK

 FILED IN 9th COURT OF APPEALS BEAUMONT, TEXAS 3/27/2018 8:54:30 PM CAROL ANNE HARLEY Clerk
CASEY MICHAEL RHYNES V. THE STATE OF TEXAS

MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

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4. On October 27, 2017, Appellant was assessed a sentence of 

fifty years confinement in the Texas Department of Criminal Justice 

Institutional Division.

5. Notice of appeal was given on November 16, 2017.

6. The Clerk’s Record was filed on February 26, 2018. The 

Reporter’s Record was filed on January 14, 2018.

7. The appellate brief is presently due on March 28, 2018.

8. Appellant requests an extension of time of 30 days from the 

present date, i.e. April 27, 2018.

9. No extensions to file the brief have been received in this 

cause.

10. Appellant is currently incarcerated.

11. Appellant relies on the following facts as good cause for the 

requested extension.

Counsel has been preparing for trial in Cause No. 17-

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

was set for trial in the County Court at Law No. 1 of 

Montgomery County, on April 2, 2018, and was resolved with 

an agreed plea of guilty on March 20, 2018.
CASEY MICHAEL RHYNES V. THE STATE OF TEXAS

MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

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Counsel has been preparing for trial in Cause No. 

17-324419, 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 of 

Barbara Ann Kmiecik, 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 to Extend Time to File Appellant’s Brief.

Respectfully submitted,

Matt Brown

Attorney at Law

332 North Main Street

Conroe, Texas 77301

832-754-7538 

936-494-1233 facsimile

matt@pmbrownlaw.com

By:
CASEY MICHAEL RHYNES V. THE STATE OF TEXAS

MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

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Matt Brown

State Bar No. 24048367

Attorney for Casey Michael Rhynes

CERTIFICATE OF SERVICE

This is to certify that on March 27, 2018, 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.

Matt Brown