NO. 14-15-00589-CR

IN THE COURT OF APPEALS FOR THE 

FOURTEENTH DISTRICT OF TEXAS 

AT HOUSTON 

-----------------------------------------------------------------

NO. 13CR1806 

IN THE 212th DISTRICT COURT OF 

GALVESTON COUNTY, TEXAS 

-----------------------------------------------------------------

ROYCE GENE ADAMS, III, APPELLANT 

V.

THE STATE OF TEXAS, APPELLEE 

 ------------------------------------------------------------------ 

MOTION FOR FOURTH EXTENSION OF 

TIME TO FILE BRIEF OF APPELLANT 

-----------------------------------------------------------------

Winston E. Cochran, Jr. 

 Attorney at Law 

Texas Bar No. 04457300 

P.O. Box 2945 

League City, TX 77574 

Tel. (713) 228-0264 

E-mail:winstoncochran@comcast.net 

Counsel for Appellant 

ACCEPTED

14-15-00589-CR

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

12/22/2015 10:29:56 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 12/22/2015 10:29:56 PM CHRISTOPHER A. PRINE Clerk
TO THE HONORABLE COURT OF APPEALS:

COMES NOW the appellant, Royce Gene Adams, III (hereinafter “Adams”), 

through the undersigned counsel, and respectfully requests that this Court grant a 

fourth, short extension of the time to file the appellant’s brief, until December 31, 

2015, for reasons set forth as follows.

1. Adams was indicted for two counts of Aggravated Sexual Assault, 

allegedly committed against a child. A jury found Adams guilty as charged on each 

count. Punishment was assessed at confinement for forty-five years in the Texas 

Department of Criminal Justice, Correctional Institutions Division, plus a fine, on 

Count One. Punishment was assessed at confinement for life, plus a fine, on Count 

Two. 

2. Adams gave timely notice of appeal on both counts. Adams also is 

appealing convictions on two counts in another case, as addressed in a separate 

motion for extension.

3. The appellant’s brief is due on December 22, 2015, pursuant to a third 

extension of time to file the brief. The appellant requests a short, fourth extension.

4. The reasons for the requested extension are as follows:

A. The undersigned counsel has decided to scale down the brief by 

abandoning certain issues relating to the guilt stage of trial. Counsel 

came to this conclusion very late in the process, and with some 
3

trepidation, but not everything that was questionable at trial makes a 

good appellate point. The key issue now will concern a 

punishment-stage jury charge request and will apply to all of the counts 

at issue in both cases. Counsel simply has not time, by the present due 

date, to make the needed structural revisions and to beef up the 

argument of the charge issue to counsel’s satisfaction.

B. Unfortunately access to resources will be limited from mid-day on 

December 23 through December 27 because of the Christmas holiday 

period. Accordingly, counsel believes some time in the week following 

Christmas is needed.

Wherefore Adams prays that the time for filing the appellant’s brief in this 

cause be extended to December 31, 2015. 

Respectfully submitted,

/s/ Winston E. Cochran, Jr.

Winston E. Cochran, Jr.

Attorney at Law

Texas Bar No. 04457300

P.O. Box 2945

League City, TX 77574

Tel. (713) 228-0264

E-mail:winstoncochran@comcast.net

Counsel for Appellant
4

CERTIFICATE OF SERVICE

I certify that a copy of this motion for extension will be served on counsel for 

the State at the following address on December 23, 2015:

Galveston County District Attorney’s Office

Appellate Division

600 59th Street

Galveston, TX 77551

/s/ Winston E. Cochran, Jr.

Winston E. Cochran, Jr.