NO. 06-14-00116-CR & 06-14-00117-CR

JOSEPH JOHN GRUBBS § IN THE

§

VS. § 6

TH COURT

§

STATE OF TEXAS § OF APPEALS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF, SECOND

TO THE HONORABLE JUSTICES OF SAID COURT: 

Now comes Joseph John Grubbs, Appellant in the above styled and numbered 

cause, and 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 354th Judicial District Court of HUNT 

County, Texas. 

2. The case below was styled the STATE OF TEXAS vs. Joseph John 

Grubbs, and numbered 29,417 & 29,725. 

3. Appellant was convicted of Unlawful Possession by a Felon in 29,417 

and Fraudulent Use/Possession of Identifying Information # Items < 5 in 29,725. 

4. Appellant was assessed a sentence of 25 years in 29,417 and 5 years in 

29,725 on July 3, 2014. 

5. Notice of appeal was given on July 8, 2014. 

ACCEPTED

06-14-00116-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

4/13/2015 11:53:30 PM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 4/13/2015 11:53:30 PM DEBBIE AUTREY Clerk
6. The clerk's record was filed on November 10, 2014; the reporter's 

record was filed on February 11, 2014.

7. The appellate brief is presently due on April13, 2015.

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

date.

9. One extension to file the brief has been received in this cause.

10. Defendant is currently incarcerated.

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

extension:

Appellant’s attorney, Jason A. Duff has begun a review the several volumes 

and exhibits contained in the reporter’s record and the clerk’s record the record of 

each case; however, Appellant’s counsel requests additional time to sufficiently 

develop the arguments material to the brief.

Counsel is set for special setting for Final Trial in Cause No 80,219, In the 

Interest of M.S., E.S. & B.M., Children in the 196th District Court; Hunt County 

Child Protection Court for Northeast Texas #2 on April 17 & 20, 2015.

Then Counsel is set for special setting for Final Trial in Cause Nos. 80,884 & 

81,156, In the Interest of F., L., & N., Children in the 196th District Court; Hunt 

County Child Protection Court for Northeast Texas #2 on April 21 & 22, 2015.

Counsel is appointed on In the Interest of J.S. Appellate Cause No. 
12-15-00053-CV, an accelerated appeal, and is working review the record from a 

four day jury trial and to timely file a brief on April 22, 2015 in that case.

Counsel is appointed on In the Interest of E.W. Appellate Cause No. 

6-15-00018-CV, an accelerated appeal, and is working review the record from the 

trial and motion for new trial record to timely file a brief on April 22, 2015 in that 

case.

Counsel is also appointed in:

Mark Eugene Engle v. State Appellate Cause number 06-14-00239-CR. 

Charles Francis Williams v. State Appellate Cause numbers 06-15-00030-CR 

& 06-15-00031-CR.

Shanna Delaine Gluck v. State Appellate Cause number 06-15-00048-CR. 

Counsel prepared for and represented his clients in an Adversarial hearings 

in Hunt County Child Protection Court for Northeast Texas #2 on April 10, 2015 in 

several separate cases.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this 

Court grant this Motion To Extend Time to File Appellant's Brief, and for such other 

and further relief as the Court may deem appropriate.

Respectfully submitted,

JASON A DUFF

2615 Lee St.
Greenville, TX 75403

Tel:903.455.1991

Fax:903.455.1417

By: /s/ Jason A. Duff

Jason A. Duff

State Bar No. 24059696

jasonaduff@hotmail.com

Attorney for Joseph John Grubbs

CERTIFICATE OF SERVICE

This is to certify that on April 13, 2015, a true and correct copy of the above 

and foregoing document was served on the District Attorney's Office, Hunt County, 

by electronic filing service.

 /s/ Jason A. Duff

Jason A. Duff