State v. Sean Michael McGuire ( 2015 )

ACCEPTED 01-14-01023-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 7/7/2015 3:24:16 PM CHRISTOPHER PRINE CLERK No. 01-14-01023-CR In the FILED IN 1st COURT OF APPEALS COURT OF APPEALS HOUSTON, TEXAS For the 7/7/2015 3:24:16 PM FIRST JUDICIAL DISTRICT CHRISTOPHER A. PRINE at Houston Clerk On Appeal from the 240th Judicial District Court of Fort Bend County, Texas in Cause Number 10-DCR-055898 THE STATE OF TEXAS, Appellant v. SEAN MICHAEL MCGUIRE, Appellee __________________________ APPELLEE’S MOTION FOR EXTENSION OF TIME ______________________________ TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS: COMES NOW, Sean Michael McGuire, Appellant herein, by and through his attorney of record, Kristen Jernigan, and files this, his Motion for Extension of Time. In support of said motion, Appellee would show this Honorable Court the following: 1. Appellee’s brief is due in this case on July 10, 2015.1 2. Appellant seeks an extension of sixty days in which to file his brief, 1 The State filed an amended brief on June 10, 2015. 1 making his brief due on or before September 9, 2015. 3. In the past thirty days, the undersigned has filed an appellate brief in the Fourteenth Court of Appeals in Cause Number 14-15-00030-CR, Miguel Macias. v. The State of Texas. The undersigned also filed appellate briefs in the Thirteenth Court of Appeals in Cause Numbers 13-14-00547-CR; 13-14-00548- CR; and 13-14-00549-CR; John Steen v. The State of Texas. In addition, the undersigned filed an appellate brief in the Fourth Court of Appeals in Cause Number 04-14-00787-CR, Matthew Aranda v. The State of Texas. Further, the undersigned drafted Proposed Findings of Fact and Conclusions of Law in the 368th District Court of Williamson County in Cause Number 13-0826-K277-CR, The State of Texas v. Crispin James Harmel. Finally, the undersigned has made numerous court appearances, has reviewed the Reporter’s Record in numerous pending appellate cases, and has undertaken other tasks pertinent to the practice of a solo attorney. 4. The undersigned has not filed any previous motions for extension of time in this case. 5. For the reasons set forth above, Appellant respectfully requests that he be granted an extension of sixty days so that his brief in this case will now be due on September 9, 2015. PRAYER WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this Court grant his Motion for Extension of Time. Respectfully submitted, /s/ Kristen Jernigan Kristen Jernigan State Bar No. 90001898 207 S. Austin Ave. Georgetown, Texas 78626 (512) 904-0123 (512) 936-1650 (fax) Kristen@txcrimapp.com 2 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Appellant’s Motion for Extension of Time has been mailed to the Fort Bend County District Attorney’s Office on July 7, 2015. /s/ Kristen Jernigan Kristen Jernigan 3