Christopher German Reyes v. State ( 2015 )

ACCEPTED 03-15-00432-CR 7751028 THIRD COURT OF APPEALS AUSTIN, TEXAS 11/9/2015 4:17:17 PM JEFFREY D. KYLE CLERK IN THE THIRD COURT OF APPEALS FOR THE STATE OF TEXAS FILED IN 3rd COURT OF APPEALS CHRISTOPHER GERMAN REYES AUSTIN, TEXAS 11/9/2015 4:17:17 PM V. NO. 3-15-00432-CR JEFFREY D. KYLE Clerk THE STATE OF TEXAS APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE THIRD COURT OF APPEALS: COMES NOW, Christopher German Reyes, by and through his attorney of record, Linda Icenhauer-Ramirez, and files this his First Motion for Extension of Time to Brief and in support thereof, would show the Court the following: I. That the above-styled and numbered cause is styled The State of Texas v. Christopher German Reyes, Cause Number D-1-DC-14-301140 in the 427th Judicial District Court of Travis County, Texas. Appellant was sentenced on June 12, 2015. II. Appellant was convicted of the offense of aggravated sexual assault of a child and punishment was assessed at thirty (30) years. III. Appellant’s motion for new trial was filed on June 12, 2015. Notice of appeal was filed on July 8, 2015. The reporter’s record was filed on September 24, 2015, and the clerk’s record was filed on October 9, 2015. The due date for the brief is Monday, November 9, 2015. IV. This is Appellant’s first motion for extension of time to file his brief. Appellant respectfully requests a forty day extension of time to file the brief, which would make such brief due on Saturday, December 19, 2015. The next working day is Monday, December 21, 2015. V. The undersigned attorney has read the record in this case and has begun drafting the brief but has been unable to complete the brief due to necessary work needed to be completed on several other appeal cases and due to her busy schedule in both the district and county courts of Travis and Williamson Counties. She asks that this extension be granted so that she may effectively represent Appellant and so that justice may be done in this case. Respectfully Submitted /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ Attorney at Law 1103 Nueces Austin, Texas 78701 (512) 477-7991 FAX #: (512) 477-3580 SBN: 10382944 EMAIL: ljir@aol.com ATTORNEY FOR APPELLANT CERTIFICATE OF COMPLIANCE I hereby certify that this motion was computer generated and contains 421 words, as calculated by the word count function on my computer. /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ CERTIFICATE OF SERVICE I, Linda Icenhauer-Ramirez, hereby certify that a true and correct copy of the foregoing Appellant’s First Motion for Extension of Time to Brief was served by e-file to the Travis County District Attorney's Office on this the 9th day of November, 2015. /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ