CASE NO. 14-15-00300-CR 

CASE NO. 14-15-00301-CR 

LASHONDA DEON JONES 

v. 

THE STATE OF TEXAS 

§ 

§ 

§ 

§ 

§ 

IN THE COURT OF APPEALS 

14th DISTRICT 

HOUSTON, TEXAS 

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF 

TO THE HONORABLE JUSTICES OF SAID COURT: 

LASHONDA DEON JONES, Appellant in the above styled and numbered case, 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 221 stJudicial District Court in Montgomery County 

Texas. 

2. The case below was styled The State of Texas vs. LASHONDA DEON JONES, 

and numbered 15-01-00219-CR. 

3. Appellant was convicted of Possession of a Controlled Substance and Tampering 

with Physical Evidence. 

4. On January 29, 2015, Appellant was assessed a sentence to forty-five (45) years 

in the Texas Department of Criminal Justice, Institutional Division on each charge to run 

concurrent. 

5. Notice of appeal was given on February 18, 2015. 

6. The Clerk's Record was filed on May 28, 2015. The Reporter's Record was filed 

on May 13, 2015. 

7. The appellate brief is presently due on August 28, 2015. 

LASHONDA DEON JONES V. THE STATE OF TEXAS 

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF 

Page 1 of 4 

ACCEPTED

14-15-00300-CR

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

8/28/2015 3:22:06 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 8/28/2015 3:22:06 PM CHRISTOPHER A. PRINE Clerk
8. Appellant requests an extension of time of 30 days from the present date, i.e. 

September 21, 2015. 

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

10. Appellant is currently incarcerated. 

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

The record in this case consists of 9 volumes consisting of Pre-Trial 

hearings, voir dire, guilt/innocence phase, punishment phase and exhibits. 

Due to the nature and severity of the sentence due diligence is required to 

properly prepare a brief on this matter. 

I have completed reviewing the record and identified numerous grounds 

that require further research and writing in order to properly represent Appellant. 

LASHONDA DEON JONES PRAYS that this Court grant this Motion to Extend Time to 

File Appellant's Brief. 

Respectfully submitted, 

Law Offices of Austin D. Black 

215 Simonton 

Conroe, Texas 77301 

936-524-3124 

936-756-3539 facsimile 

By: 

Austin D. Black 

State Bar No. 24050018 

Attorney for LASHONDA DEON JONES 

LASHONDA DEON JONES V. THE STATE OF TEXAS 

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF 

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CERTIFICATE OF SERVICE 

This is to certify that on August 28, 2015 , a true and correct copy of the above and 

foregoing document was served on the Montgomery County District Attorney's Office by e-file. 

Austin D. Black 

LASHONDA DEON JONES V. THE STATE OF TEXAS 

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF 

Page 3 of 4 
lic, State of Texas 

STATE OF TEXAS 

COUNTY OF MONTGOMERY 

AFFIDAVIT 

BEFORE ME, the undersigned authority, on this day personally appeared Austin D. 

Black, who after being duly sworn stated: 

"I the attorney for the appellant in the above numbered and styled cause. I have 

read the foregoing Motion to Extend Time to File Appellant's Brief and swear 

that all of the allegations of fact contained therein are true and correct to the best 

of my knowledge." 

Austin D. Black 

Affiant 

SUBSCRIBED AND SWORN TO BEFORE ME on 

L.A.9a9A--s6 apc to certify which witness my hand and seal of office. 

Z:FF;;:',,, STEPHANIE D. BLACK 

l'::A4411: Notary Public, State of Texas 

My Commission Expires 

........ November 08, 2017 

LASHONDA DEON JONES V. THE STATE OF TEXAS 

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF 

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