State v. Robert Simpson ( 2015 )

ACCEPTED
03-15-00499-CR
8006575
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/30/2015 10:43:21 AM
JEFFREY D. KYLE
CLERK
IN THE
THIRD COURT OF APPEALS
OF TEXAS FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
STATE OF TEXAS § 11/30/2015 10:43:21 AM
JEFFREY D. KYLE
v. § CASE NO. Clerk
3-1S-00499-CR
ROBERT SIMPSON §
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
NOW COMES, ROBERT SIMPSON, appellee In the above styled and
numbered cause, and respectfully moves the Court for an extension of time within
which to file the appellee brief, and for cause would show the Court as follows:
The appellee brief is due on October 30. This is the third requested extension
filed on behalf of the appellee. Counsel now requests an additional extension for the
following reasons:
Counsel filed two Applications for Writ of Habeas Corpus requesting out of time
Petition for Discretionary Review due to previous counsel's failure to file such on
behalf of the client in Zambrana v. State, no. 07-12-00124 and no. 07-12-00125. The
Court granted the applications. Counsel filed the two Petition for Discretionary
Reviews on Wednesday, November 25, 20] 5. Counsel is also presently working on
several other post-conviction and appellate matters. Counsel is also set for trial in State
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v. Mroos in the 187tl1 District Court of Bexar, cause no. 2015-CR-476B December 14,
2015 in a first degree manufacturing of a controlled substance.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully prays that
this motion be granted and that the Court permits an extension of time to file the
appellee brief of an additional fifteen days.
RESPECTFULLY SUBMITTED,
aniel H. Wannamaker
1012 Ri 0 Grande Street
Austin, Texas 78701
(512) 236-9929
(512) 233-5979 (Fax)
State Bar No. 20834300
Attorney for Appellant
CERTIFICA TE OF SERVICE
1 hereby certify that a true and correct copy of the foregoing Appellee's Motion
to Extend Time to File Appellee Brief was furnished to the Travis County District
Attorney's Office, on this the 30th day of November, 2015.
aniel H. Wannamaker
Attorney for Appellant
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