Angelita Rodriguez Pacheco v. State ( 2015 )

ACCEPTED 03-14-00676-CR 5674355 THIRD COURT OF APPEALS AUSTIN, TEXAS 6/15/2015 11:53:00 AM JEFFREY D. KYLE CLERK NO. 03-14-00676-CR FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS IN THE COURT OF APPEALS 6/15/2015 11:53:00 AM FOR THE JEFFREY D. KYLE THIRD SUPREME JUDICIAL DISTRICT Clerk AT AUSTIN, TEXAS ANGELITA RODRIGUEZ PACHECO, Appellant vs. THE STATE OF TEXAS, Appellee Appeal from the 424th Judicial District Court Cause No. 41988 Burnet County, Texas The Honorable Dan Mills, Judge Presiding APPELLANT'S THIRD 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 THIRD MOTION FOR EXTENSION OF TIME TO FILE BRIEF Appellant, Angelita Rodriguez Pacheco, file this, her “Third 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 June 19, 2015. 4. Appellant's attorney had a very busy trial and appellate schedule during the months of May and into June 2015. Appellant’s attorney expects he will be in trial the week of June 22, and that trial is expected to last all week. Appellant’s attorney has also just received news of his fathers passing on June 15, 2015. He will be out of the office in order to make arrangements for the funeral. 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 July 20, 2015 to complete his brief. 6. Accordingly, Appellants request that this Court allow him until July 20, 2015 to file his brief. Respectfully submitted, /s/ Gary E. Prust Gary E. Prust SBN 24056166 1607 Nueces Street Austin, Texas 78701 (512) 469-0092 Fax: (512) 469-9102 gary@prustlaw.com Attorney for Appellant 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. R. Blake Ewing with the 33rd and 424th Judicial District Attorney’s Office via electronic transmission to his email address at asstda2@burnetcountytexas.org in accordance Rule 9.5(b) of the Texas Rules of Appellate Procedure on this the 15th day of June, 2015. /s/ Gary E. Prust Gary E. Prust CERTIFICATE OF COMPLIANCE Pursuant to TEX. R. APP. PROC. 9.4(i)(3), I hereby certify this motion contains 192 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. /s/ Gary E Prust Gary E. Prust