Demitres Coleman v. State of Texas 6 th Court of Appeals No . 06

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- CR Appellant’s Second Motion fo r Extension of Time to File Brief Page 1 of 5 NO. 06

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IN THE COURT OF APPEALS SIXTH APPELLATE DISTRICT OF TEXAS AT TEXARKANA

DEMITRES COLEMAN Appellant

v.

STATE OF TEXAS Appellee

APPELLANT ’ S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE COU RT OF APPEALS:

COMES NOW the Appellant, DEMITRES COLEMAN , by and through

counsel of record, Jason Horton , and for his Second Motion for Extension of Time to

File Brief states as follows:

I.
Appellant ’s Brief is due on June 27 , 2016

.

II.
Appellant has sought and obtained one prior briefing extension in this case.

III.
Appellant requests additional time to (1) review the record for all possible
points on appeal
, and (2) prepare Appellant ’ s brief . Appellant’s counsel ’ s trial and
appellate caseload and schedule have prevented said attorney from being able to ACCEPTED 06-16-00002-cr SIXTH COURT OF APPEALS TEXARKANA, TEXAS 6/24/2016 9:37:15 AM DEBBIE AUTREY

CLERKDemitres Coleman v. State of Texas 6 th Court of Appeals No . 06

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- CR Appellant’s Second Motion fo r Extension of Time to File Brief Page 2 of 5 devote the necessary time to complete Appellant’s brief. Said caseload and schedule

includes, but is not limited to, the following since the last extension request :

■ Preparation for and attendance at pretrial hearing in State of Arkansas v.
Costello Byrd
, pending in the Circuit Court of Miller County, Arkansas, on May 31,

2016;

■ Preparation for and attendance at pretrial hearing in State of Arkansas v.

Joshua Moo ney , pending in the Circuit Court of Miller County, Arkansas, on May 31,

2016;

■ Preparation for and attendance at pretrial hearing in State of Arkansas v. Max

Harris , pending in the Circuit Court of Miller County, Arkansas, on May 31, 2016;

■ Preparat ion for and attendance at the remainder of the Miller County

criminal pre

- trial docket in the Circuit Court of Miller County, Arkansas, on May 31,

2016 ;

■ The undersigned was on vacation from June 1

- 13, 2016 ;

■ Preparation for and attendance at arraig nment in State of Arkansas vs. Julie

Aultman , pending in the Circuit Court of Miller County, Arkansas , on June 14, 2016 ;

■ Preparation for and attendance at Miller County criminal trial docket in the
Circuit Court of Miller County, Arkansas, on June 20, 2016 ;Demitres Coleman v. State of Texas 6 th Court of Appeals No . 06

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- CR Appellant’s Second Motion fo r Extension of Time to File Brief Page 3 of 5 ■ Preparation for and attendance at status hearing in State of Arkansas v.
Costello Byrd
, pending in the Circuit Court of Miller County, Arkansas, on June 20,

2016;

■ Preparation for trial and attendance at status hearing in State of Arkansas v.

Alexander Cox
, pending in the Circuit Court of Miller County, Arkansas, from June 1

-
20, 2016;

■ Preparation for and attendance at plea and sentencing in State of Texas vs.

Kaitlin Jameson , pending in the County Court at Law of Bowie County, Texas , on

Jun e 20, 2016 ;

■ Preparation for and attendance at sentencing hearing in United States v.

Narcizo Valdovinos
, pending in the United States District Court for the Eastern

District of Texas, on June 21, 2016;

■ Preparation for and attendance at administrati ve probation hearing in State of
Texas v. Heather Jessup, pending in the District Court of Bowie County, Texas, on
June 21, 2016;

■ Preparation for and attendance at status hearing in State of Texas v. Tom

Asimos
, pending in the County Court at Law of Ca ss County, Texas, on June 23,

2016;

■ Preparation for and attendance at administrative d riv er’s license hearing in
State of Arkansas v. Jacob McCann
, pending in the District Court of Clark County,Demitres Coleman v. State of Texas 6 th Court of Appeals No . 06

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- CR Appellant’s Second Motion fo r Extension of Time to File Brief Page 4 of 5 Arkansas
, on June 24, 2016; and

■ Preparation for and a ttendance at change of plea hearing in United States v.
Carlos Suyi

- Rodriguez
, pending in the United States District for the Eastern District of

Texas

- Texarkana Division, from June 26

- 27, 2016.

I V.
This motion is made in good faith and not for purposes of delay.

V I

. Without additional time, Appellant will be denied effective assistance of
counsel on appeal, to which he is entitled.

WHEREFORE , Appellant requests that th e deadline for the filing of his Brief

be extended thirty ( 30 ) days
, and for any such oth er relief to which he may be entitled.
Respectfully submitted,

JASON HORTON LAW FIRM 114 West Broad Street Texarkana, Texas 75501 Mail to: P.O. Box 1596 Texarkana, Texas 75504 T

- (903) 792

- 2000 F

- (903) 792

- 2100

BY: /s/ Jason Horton Jason Horton jas on@jasonhortonlaw.com Texas Bar Number 24041130

ATTORNEY FOR APPELLANTDemitres Coleman v. State of Texas 6 th Court of Appeals No . 06

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- CR Appellant’s Second Motion fo r Extension of Time to File Brief Page 5 of 5 CERTIFICATE OF SERVICE

On this 24 th day of June , 2016 , I hereby certify that a true and correct copy of

t he foregoing document will be served on the Bowie County District Attorney ’s

Office , according to the Texas Rules of Appellate Procedure and the rules of this

Court.

/s/ Jason Horton Jason Horton