Leovardo Cantos v. State ( 2015 )

ACCEPTED 03-14-00585-CR 5409200 THIRD COURT OF APPEALS AUSTIN, TEXAS 5/25/2015 10:34:14 PM JEFFREY D. KYLE CLERK IN THE THIRD COURT OF APPEALS FOR THE STATE OF TEXAS FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS LEVARDO CANTOS 5/26/2015 12:00:00 AM JEFFREY D. KYLE V. NO. 3-14-00585-CRClerk THE STATE OF TEXAS APPELLANT’S THIRD MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE THIRD COURT OF APPEALS: COMES NOW, Leovardo Cantos, by and through his attorney of record, Linda Icenhauer-Ramirez, and files this his Third Motion for Extension of Time to Brief and in support thereof, would show the Court the following: I. That the above-styled and numbered cause is styled The State of Texas v. Levardo Cantos, Cause Number 13-2081-K277 in the 277th Judicial District Court of Travis County, Texas. Appellant was sentenced on August 11, 2014. II. Appellant was convicted of the offense of aggravated assault with serious bodily injury and punishment was assessed at fifteen (15) years. III. Appellant’s motion for new trial was filed on September 10, 2014. Notice of appeal was filed on September 10, 2014. The reporter’s record was filed on January 15, 2015, and the clerk’s record was filed on January 15, 2015. The exhibits were filed on January 23, 2015. The due date for the brief is Tuesday, May 26, 2015. IV. This is Appellant’s third motion for extension of time to file his brief. Appellant respectfully requests a forty-five day extension of time to file the brief, which would make such brief due on Friday, July 10, 2015. V. The undersigned attorney has begun work on this case but has been unable to complete the brief due to necessary work needed to be completed on several other appeal cases and due to her busy schedule in both the district and county courts of Travis, Williamson and Hays Counties. Today she completed and filed briefs in the cases of Troy Luther Williams v. State of Texas, Cause Nos. 03-14-00228-CR and 03-14-00229-CR. In addition she is in the process of preparing petitions for discretionary review in the cases of Rodolfo Cisneros v. State of Texas, Cause Nos. 03-13-00206-CR, 03-13-00207-CR, 03-13-00208-CR, 03-13-00209-CR, all of which are due next week. She asks that this extension be granted so that she may effectively represent Appellant and so that justice may be done in this case. Respectfully Submitted /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ Attorney at Law 1103 Nueces Austin, Texas 78701 (512) 477-7991 FAX #: (512) 477-3580 SBN: 10382944 EMAIL: ljir@aol.com ATTORNEY FOR APPELLANT CERTIFICATE OF COMPLIANCE I hereby certify that this motion was computer generated and contains 470 words, as calculated by the word count function on my computer. /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ CERTIFICATE OF SERVICE I, Linda Icenhauer-Ramirez, hereby certify that a true and correct copy of the foregoing Appellant’s Third Motion for Extension of Time to Brief was served by e-file to John Prezas of the Williamson County District Attorney's Office on this the 25th day of May, 2015. /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ