CAUSE NO. 12-15-00001-CR 

OSCAR PERKINS § IN THE

§

VS. § TWELFTH COURT 

§

THE STATE OF TEXAS § OF APPEALS

MOTION TO 

EXTEND TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Appellant in the above styled and numbered cause, and 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 the 114TH Judicial District Court of Smith County,

Texas.

2. The case below was styled State of Texas v. Oscar Perkins and numbered 114-

1209-14.

3. Appellant was convicted of Assault Causes Bodily Injury to Family Member.

4. Appellant was assessed a sentence of life confinement in TDCJ-ID.

5. Notice of Appeal was given on January 2, 2015.

6. The Clerk's Record was filed on February 2, 2015; the Reporter's Record was

filed on March 24, 2015. 

7. The Appellant’s Brief is due on April 23, 2015. Counsel requests the Court an

extension of thirty (45) days due to the number of briefs with deadlines.

8. Appellant requests an extension of time due to the following facts and

circumstances.

Since the Reporter’s Record in this case was completed, Counsel has filed: 

A. Appellant’s Brief in Fredrick Perkins v. State of Texas, cause no.

12-14-00290-CR on April 3, 2015 with no further extensions;

B. Appellant’s Brief in Jolly Neely v. State of Texas, cause no. 12-14-

00309-CR on April 10, 2015 with no further extensions;

ACCEPTED

12-15-00001-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

4/23/2015 4:11:27 PM

CATHY LUSK

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 4/23/2015 4:11:27 PM CATHY S. LUSK Clerk
C. Appellant’s Brief in Robert Bagwell v. State of Texas, cause no.

12-14-00248-CR on April 10, 2015 with no further extensions; and

D. Petition for Discretionary Review in Joseph Sullivan v. State of

Texas, cause no. PD-00270-15 on April 13, 2015 with no further

extensions.

9. Counsel has appeared in numerous hearings in state and federal court over the

last thirty days, including hearings in the Eastern District of Texas - Tyler Division,

and hearings in Smith and Van Zandt Counties. Counsel attended the capital murder

seminar in Plano, Texas on March 23, 2015 through March 26, 2015. Additionally,

Counsel served as a sponsor/chaperone for the All Saints Choir when they performed

at Carnegie Hall in New York on April 2, 2015 through April 6, 2015. Lastly, Counsel

attended a CLE planning meeting with the State Bar of Texas for this year’s Advanced

Criminal Law Seminar on April 16, 2015 through April 17, 2015 in Austin, Texas.

10. Lastly, Appellant’s Counsel has the following briefs pending:

A. Appellant’s Brief in Robert Whitener v. State of Texas, cause no.

12-15-00006-CR on April 29, 2015;

B. Appellant’s Brief in Larry Maples v. State of Texas, cause no. 12-

14-00337-CR on May 1, 2015;

C. Appellant’s Brief in Donald Powell v. State of Texas, cause no. 12-

14-00355-CR on May 4, 2015;

D. Appellant’s Brief in Jason Claire Reese v. State of Texas, cause

no. 12-14-00363-CR on May 5, 2015;

E. Appellant’s Brief in Christopher Thurman v. State of Texas, cause

no. 12-15-00007-CR on May 9, 2015;

F. Appellant’s Brief in Joe Pittman v. State of Texas, cause no. 12-

15-00009-CR May 18, 2015;

G. Appellant’s Brief in Sydney Lynch v. State of Texas, cause no. 12-

15-00088-CR on May 20, 2015; 
H. Appellant’s Brief in Harold Bass v. State of Texas, cause no. 12-

15-00071-CR upon the completion of the Reporter’s Record; 

I. Appellant’s Brief in Arron McLarey v. State of Texas, cause no.

12-15-00084-CR upon the completion of the Reporter’s Record; and

J. Appellant’s Brief in Christopher McLemore v. State of Texas,

cause no. 12-15-00091-CR upon the completion of the Reporter’s

Record.

11. Appellant requests an extension of time due to the above referenced facts and

circumstances.

12. Appellant prays that this Court grant this Motion to Extend Time to File

Appellant’s Brief for a period of thirty (45) days, and for such other and further

relief as the Court may deem appropriate.

Respectfully submitted,

Law Office of James W. Huggler, Jr.

100 E. Ferguson, Suite 805

Tyler, Texas 75702

Tel: (903) 593-2400

Fax: (903) 593-3830

By: /S/ James W. Huggler, Jr.

James W. Huggler, Jr.

State Bar No. 00795437

Attorney for APPELLANT
CERTIFICATE OF SERVICE

This is to certify that on April 23, 2015, a true and correct copy of the above and

foregoing document was served on Mike West, Smith County District Attorney’sOffice,

100 North Broadway Ave., 4

th Floor, Smith County Courthouse, Tyler, Texas 75702,

by regular mail, fax, hand delivery, or electronic filing. 

 /S/ James W. Huggler, Jr.

James W. Huggler, Jr.