Michelle Elaine Gambles v. State ( 2015 )

ACCEPTED
03-14-00484-CR
5218210
THIRD COURT OF APPEALS
AUSTIN, TEXAS
5/8/2015 4:14:02 PM
JEFFREY D. KYLE
CLERK
NO. 03-14-00484-CR
FILED IN
STATEOFTEXAS § INTHE 3rd COURT OF APPEALS
AUSTIN, TEXAS
§
5/8/2015 4:14:02 PM
VS. § THIRD COURT JEFFREY D. KYLE
§ Clerk
MICHELLE ELAINE GAMBLES § OF APPEALS
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes MICHELLE ELAINE GAMBLES, Appellant in the above
styled and numbered cause, and moves this Court to grant an extension of time to
file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate
Procedure, and for good cause shows the following:
1. This case is on appeal from the County Court at Law Number 2 of
Bell County, Texas.
2. The case below was styled the STATE OF TEXAS vs. MICHELLE
ELAINE GAMBLES, and numbered 2Cl3-07485.
3. Appellant was convicted of Resisting Arrest.
4. Appellant was assessed a sentence of 6 days on July 16, 2014.
5. Notice of appeal was given on August 4, 2014.
6. The clerk's record was filed on September 5, 2014; the reporter's
record was filed on January 9, 2015.
7. The appellate brief is presently due on May 8, 2015.
8. Appellant requests an extension of time of 14 days from the present
date, i.e. May 22, 2015.
9. One extension to file the brief has been received in this cause.
10. Defendant is currently free on bond.
11. Appellant relies on the following facts as good cause for the requested
extension:
Counsel for Appellant has been preparing briefs in other cases, in addition to
normal practice placing constraints on available time.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this
Court grant this Motion To Extend Time to File Appellant's Brief, and for such
other and further relief as the Court may deem appropriate.
Respectfully submitted,
BOBBY DALE BARlNA
455 East Central Texas Expressway, Suite
104
Harker Heights, Texas 76548
Tel: (254) 699-3755
Fax: (254) 699-1074
BobbyDaleBarina@BarinaLaw.com
S e Bar No. 01738480
bobbydalebarina@barinalaw.com
Attorney for MICHELLE ELAINE
GAMBLES
CERTIFICATE OF SERVICE
This is to certify that on May 8, 2015, a true and correct copy of the above
and foregoing document was served on the County Attorney's Office, Bell County,
Bell county Justice Complex, by fax to (254) 933-5150.
-z____
DALEBARINA
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STATE OF TEXAS §
§
COUNTY OF BELL §
AFFIDAVIT
BEFORE ME, the undersigned authority, on this day personally appeared
-BOBBY DALE BARINA, who after being duly sworn stated:
"I am the attorney for the appellant in the above numbered and
entitled cause. I have read the foregoing Motion To Extend Time to
File Appellant's Brief and swear that all of the allegations of fact
contained therein are true and correct."
Af ant
SUBSCRIBED AND SWORN TO BEFORE ME on fV!4 '1' 8 , 2015,
'