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# FIFTH COURT OF APPEALS 05-15-00414-CR 05-15-00415-CR Emajin Trevon Jackson, Appellant v. State of Texas, Appellee

On Appeal from Criminal District Court No. 6 Dallas County, Texas No. F14-58177 and F14-58178


# Motion to Extend Time to File Appellant’s Brief

Michael Mowla 445 E. FM 1382 No. 3-718 Cedar Hill, Texas 75104 Phone: 972-795-2401 Fax: 972-692-6636 michael@mowlalaw.com Texas Bar No. 24048680 Attorney for Appellant ACCEPTED 05-15-00414-CR FIFTH COURT OF APPEALS

DALLAS, TEXAS 6/22/2015 12:00:00 AM

LISA MATZ CLERK2 To the Honorable Justices of the Court of Appeals: Appellant Emajin Trevon Jackson files this motion for extensio n of time to file the Appellant’s Brief moves for an extension of time to fi le the Appellant’s Brief [ See Tex. Rule App. Proc. 10.5(b) and 38.6(c)]:
1. This case is on appeal from Criminal District Court No. 6 of Da llas County, Texas.
2. The cases below are styled the State of Texas v. Emajin Trevon
Jackson , and are numbered F 14-58177 and F14-58178.
3. On March 25, 2015, sentence wa s imposed in open court.
4. Appellant was convicted of A ggravated Robbery with a Deadly Weapon in 05-15-00414-CR (F14-58177 ) and Evading Arrest in 05-1 5-00414-CR (F14-58178).
5. Appellant is presently incarcerated.
6. The reporter’s record was filed on June 11, 2015.
7. The clerk’s record was filed on May 26, 2015.
8. The Appellant’s Brief is due on July 11, 2015

. 9. Appellant requests an extension of time of 30 days from the present due date to file the Appellant’s Brief, i.e., until August 10, 2015

. 10. No previous extension to file the Appellant’s Brief has been fi led.
11. Appellant relies on the following facts as good cause for the r equested3 extension: Attorney for Appellant just completed a reply brief in Esparza v. Stephens , 4-14-CV-0694, Eastern District of Texas.
12. Further, Attorney for Appellant h as the following briefs, petit ions for discretionary review, or other pleadings due soon:

 Murray v. Texas , petition for writ of certiorari due on July 14, 2015 in the Supreme Court of the United States.

 State v. Hill III, PD-0019-15, PD-0020-15, PD-0021-15, and PD0022-15, brief due on July 10, 2 015 in the Court of Criminal Ap peals.

 Garmon v. State, PD-0596-15, petition for discretionary review due on July 13, 2015 in the Cour t of Criminal Appeals.

 Shortt v. State, PD-0597-15, petition for disc retionary review due on July 13, 2015 in the Court of Criminal Appeals.

 Zimmerman v. Cutler, et al , 15-50424, appellant’s brief due on July 21, 2015 in the Fifth Circuit.
13. In addition, Attorney for Appellant continues work on a federal habeas corpus death penalty case, Jones v. Stephens , 4:05-CV-638-Y.
14. Further, Attorney for Appellant also continues work on a state habeas corpus death penalty case, Ex parte Thomas , F86-85539, in the 194 th Judicial District Court.
15. Finally, Attorney for Appellant c ontinues work on several habea s cases involving the underlying issue in Miller v. Alabama , 132 S.Ct. 2455 (2012).
16. Attorney for Appellant has a re sponsibility to Appellant to pro vide4 Appellant with the effective assistance of appellate counsel, see Evitts v. Lucey , 469 U.S. 387, 392 (1985), and Atto rney for Appellant believes t hat that the additional time is necessary to pr ovide such effective appellat e counsel.
17. Attorney for Appellant thus reque sts the extension so that he m ay properly prepare the Appellant’s Brief in accordance with Attor ney for Appellant’s standards and to provide Appella nt the effective assistance of appellate counsel.
18. This Motion is not filed for purposes of delay, but so that jus tice may be served. Prayer Appellant prays that this motion for extension of time to file the Appellant’s Brief be granted. Respectfully submitted, Michael Mowla 445 E. FM 1382 No. 3-718 Cedar Hill, Texas 75104 Phone: 972-795-2401 Fax: 972-692-6636 Email: michael@mowlalaw.com Texas Bar No. 24048680 Attorney for Appellant

/s/ Michael Mowla Michael Mowla5 Certificate of Service I certify that on June 21, 2015, a true and correct copy of thi s document was served by email on the District Attorn ey’s Office, Dallas County, Appe llate Division to Lori Ordiway at lori.ordiway@dallascounty.org and Lisa Smith at lisa.smith@dallascounty.org.

/s/ Michael Mowla Michael Mowla