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W. DAVID
LLOYD
September 21, 1999
North Carolina Court of Appeals One W.
Morgan St. Re: State v.
Ronnie Lee Kimble 99-981 Dear Mr.
Connell: Please file
the enclosed motion to extend time. I am and
remain Sincerely yours,
/signature/ W. David Lloyd
WDL/ld Enclosure: No.
C0A99-981 EIGHTEENTH DISTRICT
STATE Or
NORTH CAROLINA Defendant
From
Guilford County THE
DEFENDANT'S MOTION TO EXTEND TIME TO FILE BRIEF THE
HONORABLE NORTH CAROLINA COURT OF APPEALS: NOW COMES
the defendant, Ronnie Lee Kimble, by and through counsel, and
respectfully moves this Court to allow him a 30-day extension until
October 26, 1999 in which to file his brief, and to accept it as
timely filed on that date. As grounds for this motion the defendant
shows the Court the following: 1.
Undersigned appointed Counsel, has experience a very heavy work load
lately. By order of this Court, the brief is currently due 30 days
from the mailing of the record which would fall on September 26,
1999. Counsel recently finished a weeklong jury trial in superior
court which required his almost total devotion. 2. In
addition, Counsel has been preparing for an upcoming capital trial,
State vs. Antone Johnson in Rockingham County. 3. Counsel
has two pending capital MAR's and a capital federal habeas action
which is still in the briefing stage. In addition counsel has
experienced the usual press of the day to day practice of law as a
sole practioner. 4. The
defendant would ask that you not punish him for the problems of his
lawyer and would grant the extension and accept as timely his brief
if filed by October 26, 1999. WHEREFORE, for the foregoing reasons, the defendant moves this Court to grant this motion. This the 21 day of September, 1999.
/signature/ W. DAVID LLOYD ATTORNEY FOR THE DEFENDANT 101 South Elm Street Ste. 310 Greensboro, North Carolina 27401 Telephone: (336) 691-0550 CERTIFICATE OF SERVICE
POST OFFICE
BOX 629
This the 21 day of September, 1999.
/signature/ W. DAVID LLOYD ATTORNEY FOR THE DEFENDANT 101 South Elm Street Ste. 310 Greensboro, North Carolina 27401 Telephone: (336) 691-0550 FILED 99 SEP 22 PM 4:04 IN THE OFFICE OF CLERK COURT OF APPEALS OF NORTH CAROLINA
No.
C0A99-981
STATE OF
NORTH CAROLINA
From
Guilford
ORDER
Witness my
hand and official seal this the 22nd day of September 1999. /signature/ John H.
Connell cc: Attorney General
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