Karra Trichele Allen v. State ( 2015 )

ACCEPTED 03-15-00420-CR 8203985 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/11/2015 2:56:03 PM JEFFREY D. KYLE CLERK NO. 03-15-00420-CR FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS IN THE COURT OF APPEALS 12/11/2015 2:56:03 PM FOR THE JEFFREY D. KYLE THIRD SUPREME JUDICIAL DISTRICT Clerk AT AUSTIN, TEXAS KARRA TRICHELE ALLEN, Appellant vs. THE STATE OF TEXAS, Appellee Appeal from the 33rd Judicial District Court Cause No. 42765 Burnet County, Texas The Honorable J. Allan Garrett, Judge Presiding APPELLANT'S SECOND MOTION FOR EXTENSION OF TIME Gary E. Prust State Bar No. 24056166 1607 Nueces Street Austin, Texas 78701 (512) 469-0092 Fax: (512) 469-9102 gary@prustlaw.com ATTORNEY FOR APPELLANT ORAL ARGUMENT IS NOT REQUESTED APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF Appellant, Karra Trichelle Allen, file this, her “Second Motion for Extension of Time to File Brief,” and in support thereof shows as follows. I. 1. Appellant's Motion is brought pursuant to TEX.R.APP.P 10.5(b). 2. Appellant has once requested previously an extension of time within which to file her brief. 3. Appellant's brief is due on December 14, 2015. 4. Appellant's attorney had a very busy trial schedule during the months of November and into December 2015. In addition, the reporter’s record in this cause is substantial, consisting of 18 volumes of transcribed hearings and an additional 3 volumes of exhibits. Appellant’s attorney also has briefs due in two other appeals the same day the brief in this cause is due. 5. In order to address the issues raised in the present appeal thoroughly, Appellant's attorney will require more time to complete his brief. Appellant’s attorney will require until February 14, 2016 to complete his brief. 6. Accordingly, Appellant requests that this Court allow her until February 14, 2 2016 to file his brief. Respectfully submitted, Gary E. Prust SBN 24056166 1607 Nueces Street Austin, Texas 78701 (512) 469-0092 Fax: (512) 469-9102 gary@prustlaw.com Attorney for Appellant 3 CERTIFICATE OF SERVICE In compliance with Rule 9.5(d) of the Texas Rules of Appellate Procedure, the undersigned attorney certifies that a true and correct copy of the foregoing Motion was served upon Mr. Gary Bunyard, assistant district attorney, via electronic transmission through efile.txcourts.gov accordance Rule 9.5(b) of the Texas Rules of Appellate Procedure on this the 11th day of December, 2015. Gary E. Prust CERTIFICATE OF COMPLIANCE Pursuant to TEX. R. APP. PROC. 9.4(i)(3), I hereby certify this brief contains 172 words. This is a computer-generated document created in Microsoft Word, using 14-point typeface. In making this this certificate, I rely on the word count provided by the software use to prepare the document. Gary E. Prust CERTIFICATE OF CONFERENCE This is to confirm I conferred with Mr. Gary Bunyard regarding this motion and he expressed no opposition. Gary E. Prust 4