NO. 12-14-00314-CR; 12-14-00315-CR; 12-14-00316-CR; 

12-14-00317-CR; 12-14-00318-CR

DANIEL WAYNE MCLEMORE.

Appellant,

VS.

THE STATE OF TEXAS,

Appellee.

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IN THE TWELFTH COURT OF

APPEALS IN AND FOR

THE STATE OF TEXAS

MOTION TO EXTEND TIME TO FILE APPELANT BRIEF

TO THE HONORABLE JUDGE OF SAID COURT: 

COMES NOW DANIEL WAYNE MCLEMORE, by and through his attorney, Wm. 

Brandon Baade, and makes this MOTION TO EXTEND TIME TO FILE APPELANT 

BRIEF: 

1. The deadline for filing the APPELANT’s Brief is June 3, 2015. 

2. APPELANT seeks and extension of fourteen (5) days from the date of filing this motion 

or June 8, 2015 to file APPELANT’s Brief.

3. Facts relied on to reasonably explain the need for an extension: 

4. Counsel was completing a brief in Cause No. 12-15-00037-CR in addition to the cases 

listed below. 

5. During the preparation of the brief in this case during the time period of the most recent 

extension it became apparent that a video of the evidence was not filed with the Court 

of Appeals or provided to counsel because for computer technology reasons, that are 

beyond counsel’s ability to understand, the video could not be provided with the 

reporters record in this case. This video was probably the most critical evidence in the 

case. 

6. I consulted with counsel for the State regarding the filing of this Motion for an 

Extension of Time and counsel for the State of Texas does not oppose this motion and is 

in agreement with the request for extension of time. 

7. Additionally, counsel has been involved in the following cases: 

ACCEPTED

12-14-00314-CR; 12-14-00315-CR; 12-14-316-CR; 12-14-00317-CR; 12-14-00318-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

6/3/2015 7:27:54 PM

CATHY LUSK

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 6/3/2015 7:27:54 PM CATHY S. LUSK Clerk
State of Texas v. Charles Eugene Louderman, Cause No. 21,728-2012 in the 402nd

Judicial District Court in and for Wood County, Texas.

State of Texas v.Nathaniel Lee Hurtzig, Cause No. 22,482-2015 in the 402nd

Judicial District Court in and for Wood County, Texas.

First National Bank of Winnsboro v. Melanie Windham, et al, Cause No. 2010-377 

in the 402nd Judicial District Court in and for Wood County, Texas.

State of Texas v. Clinton Eugene Sharp, Cause No. 22,383-2014 in the 402nd

Judicial District Court in and for Wood County, Texas.

State of Texas v. Wendy Gilbreath, Cause No. 22,410-2015 in the 402nd Judicial 

District Court in and for Wood County, Texas.

State of Texas v. Heath Allen Nutt, Cause No.22,398-2014 in the 402nd Judicial 

District Court in and for Wood County, Texas.

4. APPELANT has been granted two (2) extensions of time.

WHEREFORE, DANIEL WAYNE MCLEMORE, by his attorney, Wm. Brandon Baade, 

requests the court extend time to file APPELANT’s Brief in this case.

RESPECTFULLY SUBMITTED,

Wm. Brandon Baade

522 N Broadway Ave

Tyler, TX 75702

Tel: (903) 526-5867

brandonbaadelaw@gmail.com

 _______________________________

Wm. Brandon Baade

State Bar No. 00793189

Attorney for Appelant

CERTIFICATE OF CONFERENCE

 I certify that I have contacted Tom Burton, Attorney for Appellee, in this case and he is in 

agreement with this motion.
 _______________________________

Wm. Brandon Baade

State Bar No. 00793189

Attorney for Appellant

CERTIFICATE OF SERVICE

 I, the undersigned, hereby certify that a true and correct copy of the foregoing MOTION 

TO EXTEND TIME TO FILE APPELLANT’S BRIEF was served on all counsel of record by 

U.S. Mail on June 3, 2015.

 _______________________________

Wm. Brandon Baade

State Bar No. 00793189

Attorney for Appellant