Monte Ross v. State ( 2015 )

ACCEPTED 03-15-00222-CR 5966134 THIRD COURT OF APPEALS AUSTIN, TEXAS 7/7/2015 3:33:41 PM JEFFREY D. KYLE CLERK No. 03-15-000222-CR In the FILED IN 3rd COURT OF APPEALS COURT OF APPEALS AUSTIN, TEXAS For the 7/7/2015 3:33:41 PM THIRD SUPREME JUDICIAL DISTRICT JEFFREY D. KYLE at Austin Clerk ______________________________________ On Appeal from the 277th Judicial District Court of Williamson County, Texas Cause Number 13-1923-K277 ______________________________________ MONTE KEN ROSS, Appellant v. THE STATE OF TEXAS, Appellee _____________________________________ APPELLANT’S MOTION FOR EXTENSION OF TIME ______________________________ TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS: COMES NOW, Monte Ken Ross, Appellant herein, by and through his attorney of record, Kristen Jernigan, and files this, his Motion for Extension of Time. In support of said motion, Appellant would show the Court the following: 1. Appellant’s brief was due in this case on June 26, 2015. 2. Appellant seeks an extension of sixty days in which to file his brief, making his brief due on or before August 25, 2015. 3. In the past thirty days, the undersigned has filed a brief in the Fourteenth Court of Appeals in Cause Number 14-15-00030-CR, Miguel Macias v. The State of Texas. The undersigned also filed a brief in the Fourth Court of Appeals in Cause Number 04-14-00787-CR, Matthew Aranda v. The State of Texas. In addition, the undersigned filed briefs in the Thirteenth Court of Appeals in Cause Numbers 13-14-00547-CR; 13-14-00548-CR; and 13-14-00549-CR; John Steen v. The State of Texas. Further, the undersigned drafted proposed Findings of Fact and Conclusions of Law based on a hearing on an Application for Writ of Habeas Corpus in Cause Number 13-0826-K277, The State of Texas v. Crispin Harmel, in which multiple witnesses were called and evidence was submitted. Finally, the undersigned has made numerous court appearances and has undertaken the tasks associated with the management of a solo attorney practice. 4. The undersigned has not filed any previous motions for extension of time in this case. 5. For the reasons set forth above, Appellant respectfully requests that he be granted an extension of sixty days so that his brief in this case will now be due on August 25, 2015. PRAYER WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this Court grant his Motion for Extension of Time. Respectfully submitted, _______/s/__Kristen Jernigan______ KRISTEN JERNIGAN State Bar Number 90001898 207 S. Austin Ave. Georgetown, Texas 78626 (512) 904-0123 (512) 452-1382 (fax) Kristen@txcrimapp.com CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Appellant’s Motion for Extension of Time has been emailed to John C. Prezas, Appellate Attorney for the Williamson County District Attorney’s Office, at jprezas@wilco.org on July 7, 2015. __/s/ Kristen Jernigan__________________ Kristen Jernigan 2