Luis Ruiz Sierra v. State ( 2015 )

ACCEPTED
01-14-00493-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/16/2015 12:00:00 AM
CHRISTOPHER PRINE
CLERK
NO. 01-14-00493-CR
FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
11/16/2015 10:09:00 AM
CHRISTOPHER A. PRINE
Clerk
IN THE COURT OF APPEALS
OF TEXAS
FIRST SUPREME JUDICIAL DISTRICT
LUIS RUIZ SIERRA, APPELLANT
VS.
STATE OF TEXAS, APPELLEE
MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE APPELLANT’S BRIEF
TERRENCE GAISER
LAWYER FOR APPELLANT
2900 SMITH STREET, # 220
HOUSTON, TEXAS 77006
SBOT# 07572500
713/ 225-0666
tagaiser@aol.com
NO. 1396147
STATE OF TEXAS § IN THE DISTRICT COURT
§
VS. § HARRIS COUNTY,TEXAS
§
LUIS RUIZ SIERRA § 182ND JUDICIAL DISTRICT
MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE APPELLANT’S BRIEF
NOW COMES LUIS RUIZ SIERRA, appellant in the above-
captioned cause, by and through his attorney, TERRENCE GAISER, and
files his Motion for Extension of time within which to file Appellant’s Brief;
for which he would show:
1) This is an appeal from a conviction for the offense of burglary of a
habitation with the intent to commit the felony of sexual assault.
Punishment was assessed at thirty years confinement. Notice of appeal
and the certification of appellant’s right to appeal were timely filed.
2) This is the second requested extension of time. The brief was due
October 30, 2015.
3) Appellant would request an extension of time to file the brief to and
including the 16th day of November, 2015.
4) For good cause counsel for the appellant would show that he has not had
time to complete the brief in this cause for the following reasons:
5) For good cause counsel for the appellant would show that he has not had
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time to complete the brief in this cause for the following reasons:
a) Counsel has been in trial continuously in the death penalty trial in the
State of Texas v. William Michael Mason, Cause Number 0620074, in the
228th District Court, since Monday, October 12, 2015. This trial is not
expected to end until November 20, 2015.
b) Counsel is filing the brief contemporaneously with this motion.
c) Counsel has prepared and filed a brief in the capital murder case of
Adrian Gomez v. State of Texas, Cause Number 01-15-00383-CR, on
October 30, 2015,
d) Counsel is begging the Court for one final extension to complete and file
this brief.
c) Counsel has other briefs due in this Court and the 1st Court that he
is trying to complete.
WHEREFORE, PREMISES CONSIDERED, Appellant prays for an
extension of time to file the Appellant’s Brief to and including November
16, 2015.
RESPECTFULLY SUBMITTED,
S/Terrence A. Gaiser
TERRENCE A. GAISER
2900 SMITH STREET, # 220
HOUSTON, TEXAS 77006
SBOT# 07572500
tagaiser@aol.com
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CERTIFICATE OF SERVICE
I CERTIFY THAT A COPY OF THE ABOVE AND
FOREGOING MOTION FOR EXTENSION OF TIME WITHIN
WHICH TO FILE APPELLANT’S BRIEF WAS SERVED ON ALL
PARTIES ACCORDING TO THE RULES.
S/Terrence A. Gaiser
TERRENCE A. GAISER
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