SIXTH COURT OF APPEALS 

06-15-00023-CR 

Jessica Boyett, Appellant 

v. 

State of Texas, Appellee 

On Appeal from the 6th Judicial District Court 

Lamar County, Texas 

Cause Number 25505 

Motion to Extend Time to File 

Appellant's Brief 

THE LAW OFFICE OF KRISTIN R. BROWN 

Kristin R. Brown, Attorney 

18208 Preston Road, Suite D9375 

Dallas, Texas 75252 

P: 214-446-3909 

F: 214-481-4868 

E: kbrown@idefenddfw.com 

SBN:24081458 

ACCEPTED

06-15-00023-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

7/27/2015 12:00:00 AM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 7/27/2015 8:32:00 AM DEBBIE AUTREY Clerk
To the Honorable Justices of the Court of Appeals: 

Appellant Jessica Boyett moves for an extension of time of 30 days to 

file the Appellant's Brief [See Tex. Rule App. Proc. 10.5(b) and 38.6(c)]: 

1. This case is on appeal from the 6th Court of Appeals of Lamar 

County, Texas. 

2. The case below is styled the State of Texas v. Jessica Boyett, and is 

numbered 25505. 

3. On February 3, 2015, sentence was imposed in open court. 

4. Appellant was convicted of Conspiracy to Manufacture a 

Controlled Substance. 

5. Appellant is presently on an appeals bond, and was placed on 

community supervision for a period of three years. 

6. The reporter's record was filed on July 7, 2015. 

7. The clerk's record was filed on March 31, 2015. 

8. The Appellant's Brief is due on August 6, 2015. 

9. Appellant requests an extension of time of 30 days from the 

present due date to file the Appellant's Brief, i.e., until September 5. 2015. 

10. No previous extension to file the Appellant's Brief has been filed. 

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

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requested extension: Attorney for Appellant has suffered the loss of numerous 

close family members in the last few months, and the loss-as well as the 

travel necessitated by the loss-has put Attorney for Appellant slightly behind 

in her briefing. 

12. Further, Attorney for Appellant has the following briefs, petitions 

for discretionary review, or other pleadings due soon: 

• Ryder v. State, 07-15-00003, appellant's brief due on August 3, 

2015 in the Seventh Court of Appeals 

• Harrell v. State, 05-15-00133-CR, reply brief due in the Fifth Court 

of Appeals 

• Aday v. State, 05-14-01593, reply brief due in the Fifth Court of 

Appeals 

13. In addition, besides her regular trial docket, and additional 

upcoming appeals, Attorney for Appellant continues work on a multi-county, 

multi count case involving several felonies, and travel and investigation for 

this case have been substantial. 

14. Finally, Attorney for Appellant continues work on several habeas 

cases involving the underlying issue in Miller v. Alabama, 132 S.Ct. 2455 

(2012). 

15. Attorney for Appellant has a responsibility to provide Appellant 

with the effective assistance of appellate counsel, see Evitts v. Lucey, 469 U.S. 

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387, 392 (1985), and Attorney for Appellant believes that that the additional 

time is necessary to provide such effective appellate counsel. 

16. Attorney for Appellant thus requests the extension so that he may 

properly prepare the Appellant's Brief in accordance with Attorney for 

Appellant's standards and to provide Appellant the effective assistance of 

appellate counsel. 

17. This Motion is not filed for purposes of delay, but so that justice 

may be served. 

Prayer 

Appellant prays that this motion for extension of time to file the 

Appellant's Brief be granted. 

Respectfully submitted, 

Kristin R. Brown 

18208 Preston Road, Suite 09375 

Dallas, Texas 75252 

Phone: 214-446-3909 

Fax: 214-481-4868 

Email: kbrown@idefenddfw.com 

TexasBarNo.24081458 

Attorney for Appellant 

Kristin R. Brown 

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Certificate of Service 

This certifies that on July 26, 2015, a true and correct copy of this 

document was served on Gary Young of the District Attorney's Office, Lamar 

County, by email to gyoung@co.lamar.tx.us. 

Kris~ 

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