APPELLANT’S MOTION TO EXTEND TIME TO FILE BRIEF PAGE 1 OF 4

CAUSE NO. 03-17-00324-CR

LABESHA SHEDONNA 

COVINGTON

Appellant,

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IN THE COURT OF APPEALS

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V. § FOR THE THIRD DISTRICT

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THE STATE OF TEXAS

Appellee.

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§ AT AUSTIN, TEXAS

APPELLANT’S MOTION TO EXTEND 

TIME TO FILE APPELLANT’S BRIEF

TO THE THIRD COURT OF APPEALS OF THE STATE OF TEXAS:

NOW COMES Appellant LASHEBA SHEDONNA COVINGTON, by and 

through her attorney of record, Aaron C. Seymour, in the above entitled and 

numbered cause, and files this Appellant’s Motion to Extend Time to File 

Appellant’s Brief, and would show unto the Court the following:

I.

On the 3

rd day of May 2017, in the 35th Judicial District Court of Mills County,

Texas in Cause No. 3171, entitled The State of Texas v. LASHEBA SHEDONNA 

COVINGTON, the Appellant was convicted of the offense of Unlawful Possession 

of Firearm by Felon - Repeat and Habitual Offender, a 3rd Degree Felony, and 

sentenced to twenty-five (25) years in the Institutional Division of the Texas 

Department of Criminal Justice- TDCJ. 

ACCEPTED

03-17-00324-CR

21281424

THIRD COURT OF APPEALS

AUSTIN, TEXAS

12/13/2017 10:54 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 12/13/2017 10:54:45 PM JEFFREY D. KYLE Clerk
APPELLANT’S MOTION TO EXTEND TIME TO FILE BRIEF PAGE 2 OF 4

II.

That on the 3

rd day of May 2017, and within the time required by the Texas 

Rules of Appellate Procedure Appellant filed her written Notice of Appeal to the 

Court of Appeals for the 3rd District at Austin, Texas. The Record on Appeal was 

filed on the 16th day of May 2017. Accordingly, Appellant’s Brief in this case was 

due to be filed on the 27th day of September 2017.

III.

On November 29, 2017, Counsel filed a motion requesting an additional 

fourteen (14) days to file Appellant’s Brief. Appellant’s motion was granted and the 

deadline for submission was extended to December 13, 2017.

V.

Appellant now requests an additional extension. The facts relied upon to 

reasonably explain the need for an extension of time are as follows:

1. The record in this matter contains several DVDs admitted into evidence 

that counsel for the appellant could not review. During the past two weeks, both the 

court reporter and the district attorney’s office have offered their assistance in 

resolving this issue. And, with the use of additional software, counsel has been able

to review State’s Exhibit 1 containing DPS in-car recordings.

2. Despite working diligently with assistance from the court reporter and the 

district attorney’s office, counsel is still unable to gain access to DVDs marked as 
APPELLANT’S MOTION TO EXTEND TIME TO FILE BRIEF PAGE 3 OF 4

State’s Exhibits 2, 3, and 11, which are audio/visual recordings of the DPS vehicle 

search, DPS interviews, and the in-car video from a Mills County Sheriff’s 

Department vehicle, respectively.

3. Again, these DVDs were admitted into evidence at the Appellant’s trial. It 

is also clear from the written record that the audio/video evidence on the DVDs

played a significant role in the Court’s denial of the motion to suppress and in 

reaching it’s verdict. Review of the aforementioned exhibits is necessary to finish 

Appellant’s Brief and to properly represent the Appellant on appeal. 

WHEREFORE, PREMISES CONSIDERED, Appellant requests this

Appellant’s Motion to Extend Time to File Appellant’s Brief be GRANTED, that 

the Court extend the time for the filing deadline until December 29, 2017, and for 

such other and further relief to which Appellant may be entitled or shall ever pray.

Respectfully submitted,

THE LAW OFFICE OF 

AARON C. SEYMOUR, PLLC

311 N. Center Ave., Ste. 107

Brownwood, Texas 76801

Tel: (325) 805-4848

Fax: (325) 805-4854

By:

Aaron C. Seymour

State Bar No. 24094943

aaron@seymour-lawoffice.com

Attorney for the Appellant
APPELLANT’S MOTION TO EXTEND TIME TO FILE BRIEF PAGE 4 OF 4

CERTIFICATE OF SERVICE

This is to certify that on December 13, 2017 a true and correct copy of the 

foregoing document was sent to the 35th District Attorney’s Office in Brownwood, 

Texas by electronic filing manager. 

Aaron C. Seymour

Attorney for the Appellant