NO. 06-15- 0005 9- CR

JAMES WAYNE WALSH § IN THE § VS. § 6 TH COURT § SATE OF TEXAS § OF APPEALS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF , 2 ND
TO THE HONORABLE JUSTICES OF SAID COURT: Now comes James Wayne Walsh, 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 196 TH Judicial District Court of Hunt County, Texas.
2. The case below was styled the STATE OF TEXAS vs. James Wayne Walsh, and numbered 28,919.
3. Appellant was convicted of Evading Arrest with a Vehicle
4. Appellant was assessed a sentence of 45 years on February 12, 2015.
5. Notice of appeal was given on February 17, 2015.
6. The clerk's record was filed on April 22, 2015; the reporter's record was filed on April 20, 2015. ACCEPTED 06-15-00059-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 7/1/2015 5:20:34 PM DEBBIE AUTREY

CLERK7. The appellate brief is presently due on July 1, 2015.

8. Appellant requests an e xtension of time of 30 days from the present date, i.e. July 3 1, 2015.
9. No extension to file the brief has been received in this cause.
10. Defendant is currently i ncarcerated.
11. Appellant relies on the following facts as good cause for the requested

ex tension: Appellant’s attorney, Jason A. Duff has begun a review the several volumes in the reporter’s record and the clerk’s record the record; however, Appellant’s
counsel requests additional time to sufficiently develop the arguments material to the brie f. Counsel is also appointed in: Mark Eugene Engle v. The State of Texas , Appellate Case Number: 06

- 14

- 00239

- CR with a brief Due also on July 1, 2015. Shahid Karriem Ansari, III. v. The State of Texas , Appellate Case Number:
06

- 14

- 00220

- CR with a brief Due on July 22, 2015. Pamela Diane Contreras v. The State of Texas , Appellate Case Number: 0 5

- 1 5

- 00 544

- CR

. Charles Francis Williams v. The State of Texas , Appellate Cause Numbers:
06

- 15

- 00030

- CR and 06

- 15

- 00031.Counsel prepared for and represented his client in for a Tempora ry

Restraining Order Hearing June 18, 2015 Cause No. 76,055 in the 354 th Judicial District of Hunt County. Counsel prepared for and represented his client in for a Temporary Restraining Order Hearing June 30, 2015 Cause No. 82,028 in the 354 th Judicial District of Hunt County. Counsel prepared for and represented his clients for a Final Trial of two related Termination of Parental rights cases in In the Interest of J.N. and J.N. in Cause No 81,156 in the 196 th District Court and In the Interest of J.F., J.L and J.N. in Cause No 80,884 in the 196 th Distr ict Court on May 28, 2015 which was continued and contested for the entire day of June 19, 2015. Counsel prepared for and represented his clients in Adversarial hearings in Hunt County Child Protection Court for Northeast Texas #2 on June 26 , 2015 , whic h was not completed until after 5 pm and on July 1 , 2015 in several separate

cases. WHEREFORE, PREMISES CO NSIDERED , Appellant prays that this Court grant this Motion To Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate. Respectfully submitted,
JASON A DUFF 2615 Lee St.P.O. Box 11 GREENVILLE, TX 750 69 Tel: 903.455.1991 Fax: 903.455.1417

By: /s/ Jason A. Duff Jason A. Duff State Bar No. 24059696 jasonaduff@hotmail.com Attorney for James Wayne Walsh

CERTIFICATE OF SERVICE This is to certify that on J uly 1, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Hunt County, by electronic service through the Electronic Filing Manager.

/s/ Jason A. Duff Jason A. Duff