Jennifer Leann Watson v. State ( 2015 )


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  •                                                                                             ACCEPTED
    01-15-00134-CR
    FIRST COURT OF APPEALS
    HOUSTON, TEXAS
    7/15/2015 7:26:50 PM
    CHRISTOPHER PRINE
    CLERK
    No. 01-15-00134-CR
    JENNIFER LEANN WATSON                         §   IN THE COURT OF  APPEALS
    FILED IN
    1st COURT OF APPEALS
    §                 HOUSTON, TEXAS
    VS.                                           §   FOR THE FIRST   DISTRICT
    7/15/2015 7:26:50 PM
    §             CHRISTOPHER A. PRINE
    THE STATE OF TEXAS                            §   OF TEXAS          Clerk
    MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF
    TO THE HONORABLE JUSTICES OF SAID COURT OF APPEALS:
    COMES NOW Jennifer Leann Watson, Appellant, by and though her
    undersigned attorney of record, and files this Motion to Extend Time to File
    Appellant’s brief herein, and as sufficient cause therefore shows the following
    facts within the personal knowledge of Appellant’s attorney:
    I.
    Appellant was indicted for the felony offense of Possession With Intent to
    Deliver a Controlled Substance. Appellant pled guilty and was placed on deferred
    adjudication community supervision for a period of three years. The State
    subsequently filed a motion to adjudicate guilt alleging that Appellant violated the
    conditions of her community supervision. Appellant pled true to the motion to
    adjudicate without any agreed recommendation from the State, and the trial court
    found Appellant guilty and sentenced her to serve six years in prison. Appellant
    filed timely written notice of appeal.
    1
    II.
    On June 17, 2015, Appellant’s attorney received notice from this Honorable
    Court of Appeals that Appellant’s first motion to extend time to file Appellant’s
    brief had been granted, making Appellant’s brief due on or before July 15, 2015.
    III.
    Appellant’s attorney hereby requests that the due date for Appellant’s brief
    be extended by a period of 30 days until August 14, 2015. This is Appellant’s
    second request for an extension in this matter.
    IV.
    The facts relied upon to reasonably explain the need for the requested
    extension are as follows:
    Appellant’s attorney is a solo practitioner who had a full schedule of court
    appearances on pending felony cases since June 15, 2015. In addition, during this
    same period Appellant’s attorney was involved in pre-trial preparations in five
    pending felony trial cases, four of which were set for jury trial the week of July 6,
    2015. Further, Appellant’s attorney was involved in reviewing records and
    researching points of error in nine other pending direct appeals, including three
    with briefs filed the week of July 6, 2015. And finally, Appellant’s attorney was
    out of town on a previously scheduled family vacation for a period of two weeks.
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    Given the foregoing facts, Appellant’s attorney did not have adequate time
    available to properly review the appellate record, fully research potential points of
    error, and draft and file an appropriate appellate brief on Appellant’s behalf by the
    current due date of July 15, 2015.
    WHEREFORE, ALL PREMISES CONSIDERED, Appellant prays that this
    Honorable Court of Appeals will grant this motion and extend the time to file
    Appellant’s brief for a period of 30 days to August 14, 2015.
    Respectfully Submitted,
    /s/ Randall J. Ayers
    _________________________
    Randall J. Ayers
    Attorney for Appellant
    State Bar #01465950
    P.O. Box 1569
    Houston, Texas 77251-1569
    rjayerslaw@comcast.net (e-mail)
    281-493-6333 (office)
    281-493-9609 (fax)
    3
    CERTIFICATE OF SERVICE
    I certify that I served the foregoing motion on the District Attorney of Harris
    County, Texas, by sending a copy to Mr. Alan Curry, Chief of the Appellate
    Division, Harris County District Attorney’s Office, via electronic service to
    curry_alan@dao.hctx.net on July 15, 2015.
    /s/ Randall J. Ayers
    _________________________
    Randall J. Ayers
    Attorney for Appellant
    State Bar #01465950
    P.O. Box 1569
    Houston, Texas 77251-1569
    rjayerslaw@comcast.net (e-mail)
    281-493-6333 (office)
    281-493-9609 (fax)
    CERTIFICATE OF COMPLIANCE
    Pursuant to the provisions of Rule 9(i)(3) of the Texas Rules of Appellate
    Procedure I certify that this document contains 601 words.
    /s/ Randall J. Ayers
    _________________________
    Randall J. Ayers
    Attorney for Appellant
    State Bar #01465950
    P.O. Box 1569
    Houston, Texas 77251-1569
    rjayerslaw@comcast.net (e-mail)
    281-493-6333 (office)
    281-493-9609 (fax)
    4
    

Document Info

Docket Number: 01-15-00134-CR

Filed Date: 7/15/2015

Precedential Status: Precedential

Modified Date: 9/29/2016