### 1 CAUSE NO. 02

- 16

- 00327

- CR

SAMUEL DEWON WALKER, * COURT OF APPEALS

APPELLANT *

*

VS. * SECOND DISTRICT OF TEXAS

*

THE STATE OF TEXAS, *

APPELLEE * FORT WORTH

FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE

APPELLANT'S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Rebekah R. Syck, attorney for Appellant Samuel Dewon Wal ker, files this Motion for

Extension of Time to File Appellant's Brief and in its support shows the Court as follows:

1. This Motion is brought pursuant to T.R.A.P. 38.6 (d) and 10.5(b).

2. Appellant's brief is currently due to be filed on or before Monday, November 14, 2016.

3. Counsel for Appellant respectfully requests an additional 30 days to file Appellant’s brief.

4. Appellant is currently incarcerated in th e Wichita County, Texas jail.

5. This motion is unopposed.

6. In support of this request, Appellant's counsel advises this Honorable Court as follows:

a. This is an appeal of convictions for aggravated kidnapping, assault with a previous

conviction, unlawful p ossession of a firearm by a felon, and violation of a protective order

.

Appellant plead not guilty to the charge s

, and the jury convicted him and sentenced him to two life

sentences, a 35 year sentence, and a 40 year sentence, to be served concurrently.

b. I was appointed as co unsel on this case on October 7, 2016 , aft er the Court granted

trial court counsel Rickey Bunch’s motion to withdraw as counsel.

c. I obtained the record in this case during October. During my review, I discovered ACCEPTED

02-16-00327-CR

SECOND COURT OF APPEALS

FORT WORTH, TEXAS

11/11/2016 2:48:50 PM

DEBRA SPISAK

CLERK

### 2

that Defendant’s Exhibit 2, an audio recording, was not included in the record. I conferred with the

court reporter, Leslie Ryan

- Hash, and she later provided me with a copy of the audio recording. I

picked up the copy from the district clerk’s office on November 9, 2016

.

d. Appellant’s counsel, in addition to pr eparing the brief in this case, must also devote

time to the following addi tional matters: (1) p reparing an appellate brief to the Fifth Circuit Court

of Appeals in USA v. Nancy Freeman, No 16

- 11024, (2) preparing for hearings on numerous

misdemeanor matters in Wichita County Courts at Law #1 and #2, and (3) preparing for civil

commitment hearings in Wichita County during the month of November.

e. Appellant’s counsel is a sole practitioner who handles all legal and most of the

administrative duties of her practice.

7

. The undersigned has conferred with opposing counsel, who indicated there was no

opposition to this request.

Therefore, Appellant's counsel requests that this Court extend the deadline for fi ling of

Appellant’s brief by 30 days.

Respectfully submitted,

_/s/ Rebekah R. Syck

Rebekah R. Syck

Attorney for Appellant

3808 Kemp Blvd., Ste. B, #105

Wichita Falls, TX 76308

(940) 249

- 4494

(940) 687

- 9090 FAX

rrsyck@gmail.com

TSB# 24051872

### 3 CERTIFICATE OF CONFERENCE

On the 10 th day of November, 2016, I conferred via email with Ms. Jennifer Ponder , counsel

for Appellee, regarding the nature and su bstance of this motion, and Ms. Ponder indicated that s he

was not opposed to the relief sought.

_ /s/ Rebekah R. Syck

Rebekah R. Syck

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing First Unopposed Motion for

Extension of Time to File Appellant's Brief was serve d upon Ms. Jennifer Ponder on the 11 th day of

November, 2016 , by email via efile.

_ /s/ Rebekah R. Syck

Rebekah R. Syc k