NO. 14- 15 -00589- CR
IN THE COURT OF APPEALS FOR THE

FOURTEENTH DISTRICT OF TEXAS

AT HOUSTON

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

NO. 13CR1806
IN THE 212 th 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

CLERKTO 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 D ecember 3 1 , 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 as sessed 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 o n December 22 , 2015, pursuant to a third extension of time to file the brief. The appellant requests a short , fourth e xtension. 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 relatin g to the guilt stage of trial. Counsel came to this conclusion very late in the process, and with some3 trepidation, but no t 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 nee ded structura l 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 bel ieves some time in the wee k 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. W inston 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 Appellant4 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 59 th Street Gal veston, TX 77551

/s/ Winston E. Cochran, Jr. Winston E. Cochran, Jr.