NO. 12-14-00263-CR

STATE OF TEXAS § IN THE

§

VS. § 12th COURT

§

JEFFREY ARLEN QUINN § OF APPEALS

SECOND MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes JEFFREY ARLEN QUINN, Appellant by and through his 

attorney of record, JOHN L. YOUNGBLOOD, 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 3rd Judicial District Court of 

Henderson County, Texas.

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

ARLEN QUINN, and numbered C-20,818.

3. Appellant was convicted of Evading Arrest with a Motor Vehicle.

4. Appellant was assessed a sentence of 17 years confinement in Texas 

Department of Criminal Justice - Institutional Division on June 19, 2014.

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

ACCEPTED

12-14-000263-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

4/16/2015 4:11:53 PM

CATHY LUSK

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 4/16/2015 4:11:53 PM CATHY S. LUSK Clerk
6. The clerk's record was filed on October 17, 2014; the reporter's record

was filed on February 17, 2015.

7. The appellate brief was first due on March 19, 2015. Counsel

respectfully requested this Court to grant an extension at that time. This Court

granted said request and Ordered that Appellant’s Brief be filed on April 17, 2015.

8. Appellant requests a second extension of time of 30 days from this

immediate date for reasons as set forth herein.

9. This Court has granted one previous extension to file the brief.

10. Defendant is currently incarcerated.

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

extension:

Counsel has been appointed on two criminal cases in the past 30 days

involving indicted, habitual offenders in (a) The State of Texas vs. Jeffery

Wheeler, Cause No. CR15-0038-392, pending in the 392nd Judicial District Court,

and (b) The State of Texas vs. Billy Ray Minchew, Cause No. CR15-0008-392,

pending in the 392nd Judicial District Court. Both of these cases have involved

significant factual and legal investigation involving defendants facing a range of

punishment no less than 25 years and no more than life in prison.

Counsel was also appointed to represent an inmate on an out of time appeal

granted by the Court of Criminal Appeals in a case styled The State of Texas vs.
Lester Rainwater, Cause No. C-14,699, pending in the 3

rd Judicial District Court,

Henderson County, Texas. The mandate was issued by the Court of Criminal

Appeals on March 9, 2015 and Defendant is serving a life sentence.

Counsel has also been involved in a Motion to Suppress in a capital murder

case styled The State of Texas vs. Raheem Mark Miller, Cause Number B-21,539,

in the 392nd Judicial District Court. Such hearing was concluded today, April 16,

2015 and involved substantial factual and legal investigation in order to properly

prepare.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this

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

such other and further relief as the Court may deem appropriate.

Respectfully submitted,

JOHN L. YOUNGBLOOD

130 East Corsicana Street

Suite 300

Athens, Texas 75751

Tel: (903) 675-5188

Fax: (903) 677-3902

By: /s/ John L. Youngblood 

JOHN L. YOUNGBLOOD

State Bar No. 24003222

John@johnlyoungbloodlaw.com

Attorney for JEFFREY ARLEN QUINN
CERTIFICATE OF SERVICE

This is to certify that on April 16, 2015, a true and correct copy of the above

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

County, 109 West Corsicana Street, Suite 103, Athens, Texas 75751, by electronic

service through the Electronic Filing Manager.

 /s/ John L. Youngblood 

JOHN L. YOUNGBLOOD
STATE OF TEXAS §

§

COUNTY OF HENDERSON §

AFFIDAVIT

BEFORE ME, the undersigned authority, on this day personally appeared

JOHN L. YOUNGBLOOD, who after being duly sworn stated:

"I am the attorney for the appellant in the above numbered and

entitled cause. I have read the foregoing Second Motion To Extend

Time to File Appellant's Brief and swear that all of the allegations of

fact contained therein are true and correct."

 /s/ John L. Youngblood 

JOHN L. YOUNGBLOOD

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME on April 16, 2015, to

certify which witness my hand and seal of office.

/s/ Terri Crawford

Notary Public, State of Texas