James Michael Reser v. State ( 2015 )

ACCEPTED
03-15-00469-CR
7918756
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/20/2015 9:26:26 AM
JEFFREY D. KYLE
CLERK
No. 03-15-00469-CR
FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
JAMES MICHAEL RESER, § IN THE 11/20/2015
COURT 9:26:26 AM
OF APPEALS
JEFFREY D. KYLE
Appellant Clerk
V. § THIRD DISTRICT
THE STATE OF TEXAS, § AUSTIN, TEXAS
Appellee
APPELLANT’S MOTION FOR EXTENSION OF TIME
FOR FILING APPELLANT’S BRIEF
Pursuant to Rules 38.6(d) and 10.5(b), Texas Rules of Appellate
Procedure, Appellant respectfully moves for an extension of time to file
appellant’s brief herein, and in support of said motion would show the
following:
I.
The original deadline for the filing of appellant’s brief is November
23, 2015.
II.
Appellant’s seeks a 45 day extension of time for filing appellant’s
brief, i.e. to January 7, 2016.
III.
There have been no previous requests for an extension of time to file
appellant’s brief either sought or granted.
IV.
The facts relied upon to reasonably explain the need for an extension
are as follows:
1. The appellate record in this case is lengthy. The
Reporter’s record consists of 14 volumes plus an
additional volume of exhibits. The Clerk’s Record
consists of 194 pages.
2. Attorney for Appellant is a solo practicioner with a
civil and criminal practice practicing in Williamson
and surrounding counties in both state and federal
courts. Since receiving the reporter’s record, attorney
has had court appearances in Williamson and Bastrop
counties.
3. Attorney for Appellant also serves as Of Counsel to
the Law Firm of Charles Lance in addition to her own
practice, assisting Mr. Lance when the need or
opportunity arises.
WHEREFORE, appellant prays that this Motion for Extension of
Time for Filing Appellant’s Brief be granted and that the deadline for filing
appellant’s brief be extended to January 7, 2016.
Respectfully submitted,
LAW OFFICE OF JANA K. MCCOWN
By: /s/ Jana K. McCown
Jana K. McCown
State Bar No. 14085100
3613 Williams Drive, Suite 102
Georgetown, Texas 78628
Telephone: (512) 635-7575
Facsimile: (512) 868-2229
jkmccownlaw@gmail.com
CERTIFICATE OF SERVICE
A copy of the foregoing Appellant’s Motion for Extension of Time for
Filing Appellant’s Brief was served on November 18, 2015, in compliance
with Rule 9.5, Texas Rules of Appellate Procedure through the electronic
filing manager and in compliance with Third Court of Appeals Local Rule
3(c), on Assistant District Attorney John Prezas with the Williamson County
District Attorney’s office.
/s/ Jana K. McCown
Jana K. McCown
CERTIFICATE OF CONFERENCE
On November 18, 2015, Attorney for Appellant held a telephone
conference with Assistant District Attorney John Prezas, the appellate
attorney for the Williamson County District Attorney’s office regarding this
Motion for Extension of Time for Filing Appellant’s Brief. Mr. Prezas
advised counsel that he has no objection to the Court granting the motion.
/s/ Jana K. McCown
Jana K. McCown
No. 03-15-00469-CR
JAMES MICHAEL RESER, § IN THE COURT OF APPEALS
Appellant
V. § THIRD DISTRICT
THE STATE OF TEXAS, § AUSTIN, TEXAS
Appellee
ORDER ON APPELLANT’S MOTION FOR EXTENSION OF TIME
FOR FILING APPELLANT’S BRIEF
On this ____ day of ____________________, 2015, came on to be
considered the Motion for Extension of Time for Filing Appellant’s Brief;
and the court, having considered said motion, finds that it should be and is
hereby GRANTED.
It is, therefore, ordered that Appellant shall have until January 7,
2016, to file appellant’s brief herein.
__________________________________
Justice, Third Court Of Appeals