COURT OF APPEALS 

SECOND DISTRICT OF TEXAS 

__________________________________________________________________

MYRON J. NASH, §

 Appellant §

§

v. § NO. 02-17-00236-CR

§ NO. 02-17-00237-CR

STATE OF TEXAS, §

 Appellee §

§

APPELLANT’S SECOND UNOPPOSED MOTION FOR EXTENSION OF 

TIME TO FILE ORIGINAL BRIEF 

TO THE HONORABLE JUDGES OF SAID COURT: 

 COMES NOW, MYRON J. NASH, Appellant in the above-styled and 

numbered causes, by and through his court-appointed attorney, Jack V. Strickland, 

and files this, appellant’s second unopposed motion for extension of time to file 

original brief in these causes. In support of said motion, Appellant shows as follows: 

1.

 That on July 11, 2017, Appellant pled not guilty to one case of sexual assault 

and not true to a family violence notice and not guilty to one case of 

tampering/fabrication of physical evidence. On July 13, 2017, a jury found Appellant 

guilty of the first case, and also found the family violence notice to be true. In 

ACCEPTED

02-17-00237-CR

SECOND COURT OF APPEALS

FORT WORTH, TEXAS

12/11/2017 1:44 PM

DEBRA SPISAK

CLERK

 FILED IN 2nd COURT OF APPEALS FORT WORTH, TEXAS 12/11/2017 1:44:23 PM DEBRA SPISAK Clerk
addition, Appellant was found guilty of tampering. Jury punishment having been 

waived by Appellant, the court found the repeat offender notices to be “true”, and 

sentenced Appellant to thirty years and ten years IDTDCJ, respectively, with the 

sentences running concurrently.

2.

That the clerk’s record and the court reporter’s record have now been 

completed and filed with this court. Appellant’s original brief is due on or before 

December 12, 2017. The clerk’s record is comprised of two volumes in excess of 

250 pages and eight volumes of reporter’s record and is therefore voluminous.

 3.

That counsel did not participate in the trial of this cause.

4.

That Appellant is incarcerated and is indigent.

5.

That Appellant requires additional time to complete the drafting, 

completion, and filing of the brief in these causes. Counsel is a sole practitioner 

and is wholly responsible for the preparation of this brief, as well as the defense of 

approximately 90 additional criminal cases including three capital murder cases, 

five appellate matters at various stages of resolution, and numerous other serious 
criminal cases involving first, second and, third degree felony allegations. Said 

cases are pending in Tarrant, Parker, Dallas, and McLennan counties. 

6. 

 That within the past thirty days counsel has spent significant time preparing 

for the trial of a capital murder case docketed for January 8, 2018; has tried an 

aggravated sexual assault of a child case; has spent significant time preparing for 

the punishment phase of that trial, now docketed to begin on December 14, 2017; 

has prepared and filed a petition for discretionary review and is preparing a second 

petition for discretionary review in another case; is conducting a seminar in 

Plano, Texas, on December 11-12, 2017; and has disposed of first, second, and 

third degree felony cases in Tarrant, Parker, and Dallas counties. On a personal 

note, counsel will be out of town on December 15-16, 2017, to attend funeral 

services for his sister-in-law.

 7.

That this motion is not merely for purposes of delay but in order that justice 

may be done.

WHEREFORE, PREMISES CONSIDERED, Appellant requests that the 

Court grant this unopposed motion for an extension of sixty days in which to file his
original brief, ordering the brief due on or before February 12, 2018.

Respectfully submitted,

/s/ Jack V. Strickland

Jack V. Strickland

909 Throckmorton Street

Fort Worth, Texas 76102

Tel: 817.338.1000 (phone)

Fax: 817.338.1020 (fax)

jvstrickland1943@gmail.com

State Bar No. 19397000

COUNSEL FOR APPELLANT

(On Appeal Only)

CERTIFICATE OF CONFERENCE

On December 11, 2017, a telephone conversation was held with Assistant 

District Attorney Debra Windsor concerning the foregoing motion. Ms. Windsor 

has no objection to the motion.

/s/ Jack V. Strickland

Jack V. Strickland

CERTIFICATE OF SERVICE

On December 11, 2017, a true and correct copy of the foregoing motion was 

forwarded to Ms. Debra Windsor at coaappellatealerts@tarrantcountytx.gov.

/s/ Jack V. Strickland

Jack V. Strickland