NO. 06-14-00234-CR NO. 06-14-00235-CR

MELVIN WAYNE § IN THE COURT OF APPEALS RICHARDSON V. § FOR THE SIXTH DISTRICT STATE OF TEXAS § OF TEXAS AT DALLAS

SECOND MOTION FOR AN EXTENSION OF TIME

TO FILE APPELLANT’S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: COMES NOW, Melvin Wayne Richardson, Appellant in the above named cause number, by and through his duly appointed attorney on appeal, and requests that this Court extend the time for filing Appellant’s brief from March 30, 2015 to April 29, 2015.

I. In trial case number F06-62662, on May 10, 2010, Appellant was pled guilty to the indictment and was convicted in the 195th Judicial District Court in Dallas County, Texas of aggravated assault with a dangerous weapon. (CR1: 29 1 ). The jury assessed punishment at 40 years’

1 CR1 refers to the District Court Clerk’s record in F06-68662. ACCEPTED 06-14-00234-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 3/27/2015 2:02:01 PM DEBBIE AUTREY

CLERKimprisonment. (CR1: 26, 29 2 ). After filing an application for an 11.07 writ

of habeas corpus with the Texas Court of Criminal A ppeals, that Court issued an opinion on November 19, 2014 granting App ellant an appeal out of time. (CR1: 34-37). Appellant subsequently file d a timely notice of appeal. (CR1: 38). In trial case number F06-62371, on May 10, 2010, A ppellant was pled guilty to the indictment and was convicted in the 1 95th Judicial District Court in Dallas County, Texas of unlawful possessio n with intent to deliver cocaine, 4G. (CR2: 23 3 ). The jury assessed punishment at 25 years’ imprisonment. (CR2: 23, 29 4 ). After filing an application for an 11.07 writ of habeas corpus with the Texas Court of Criminal A ppeals, that Court issued an opinion on November 19, 2014 granting App ellant an appeal out of time. (CR2: 30-33). Appellant subsequently file d a timely notice of appeal. (CR2: 36).

II.

The due date for Appellant’s Brief is March 30, 201 5.

III.

2 The trial court entered an order Nunc Pro Tunc corr ecting the judgment from twenty years to forty years. (CR1: 26). 3 CR2 refers to the District Court Clerk’s record in F06-62371. 4 The trial court entered an order Nunc Pro Tunc cor recting the judgment from forty years to twenty-five years. (CR2: 29).Appellant requests an extension of time of thirty ( 30) days in which to

file his Brief. One previous extension of time has been requested by Appellant.

IV. Appellant submits that a reasonable explanation exi sts for this requested extension. Appellant relies on the follow ing facts to reasonably explain why the brief has not yet been prepared and the need for an extension of time in which to file Appellant’s Brie f: (1) The undersigned attorney filed a petition for d iscretionary review in cause number PD-1541-14 styled Leonardo Geronimo Renteria Sanchez v. State of Texas on December 18, 2014 pending in the Texas Court of Criminal Appeals, Austin, Texas. (2) The undersigned attorney filed a brief in cause number 05-13- 01710-CR styled Errington Charles Hatch v. State of Texas on January 31, 2015 pending in the 5 th District Court of Appeals, Dallas,

Texas. (3) The undersigned attorney filed a brief in cause number 08-14- 00208-CR styled Danielle Lozono v. State of Texas on February 17, 2015 pending in the 8 th District Court of Appeals, El Paso, Texas.(4) The undersigned attorney filed a brief in cause number 05-14-

00447/00448/00449/00450/00451-CR styled Chason Matthew Oden v. State of Texas on February 20, 2015 pending in the 5 th District Court of Appeals, Dallas, Texas. (5) The undersigned attorney filed a brief on March 4, 2015 in cause number 05-14-00720-CR styled Raymond Edwards III v. State of

Texas pending in the 5 th District Court of Appeals, Dallas, Texas. (6) The undersigned attorney filed a brief in cause numbers 05-14- 00331/00332/00333/00334-CR styled Neko Boykin v. State of Texas on March 13, 2015 pending in the 5 th District Court of Appeals, Dallas, Texas. (7) The undersigned attorney filed a brief in cause numbers 05-14- 00101-CR styled Natalio Juarez, Jr. v. State of Texas on March 20, 2015 pending in the 5 th District Court of Appeals, Dallas, Texas. (8) The undersigned attorney is preparing a brief i n cause numbers 05- 14-01050-CR styled Ronnie Creig Wilson v. State of Texas pending in

the 5 th District Court of Appeals, Dallas, Texas.

V. This Motion is not brought for purposes of delay bu t so that the appellate record can be read and evaluated, and so that the legal and factualissues presented by the appellate record can be pro perly briefed and

presented to this Court on Appellant’s behalf. WHEREFORE, Appellant requests this Court extend Ap pellant’s deadline to file its brief to April 29, 2015. Respectfully submitted,

/s/ Nanette Hendrickson Lynn Pride Richardson Nanette Hendrickson Chief Public Defender Assistant Public Defender Dallas County, TX Texas State Bar No. 24081423 Frank Crowley Courts Building 133 N. Riverfront Blvd., LB-2 Dallas, Texas 75207-4399 (214) 653-3582 (phone) (214) 653-3539 (

fax)

CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing motion was served on the Dallas County Criminal District Attorney’s O ffice (Appellate Division), 133 N. Riverfront Blvd., B-19, 10th Floo r, Dallas, Texas, 75207, by hand delivery and electronic service at DCDAAppeals@dallascounty.org on March 27, 2015.

/s/ Nanette Hendrickson Nanette Hendrickson