Pedro P. Morales v. State ( 2015 )

ACCEPTED 03-15-00281-CR 6378176 THIRD COURT OF APPEALS AUSTIN, TEXAS 8/6/2015 8:39:01 AM JEFFREY D. KYLE No. 03-15-00281-CR CLERK PEDRO P. MORALES, ) COURT OF APPEALS, THIRD Appellant ) FILED IN 3rd COURT OF APPEALS ) AUSTIN, TEXAS VS. ) SUPREME JUDICIAL DISTRICT 8/6/2015 8:39:01 AM ) JEFFREY D. KYLE STATE OF TEXAS, ) Clerk Appellee ) AUSTIN, TEXAS APPELLANT'S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Appellant, by and through his attorney of record, and respectfully files this his Second Motion for Extension of Time to File Brief and requests this extension of time to file his appellate brief in this cause herein, and for cause would show the Court the following: I. The Appellant, PEDRO P. MORALES, was sentenced in Cause number C-1 0- 0321-SB, in the 3401h District Court of Tom Green County, Texas, to ten (10) years confinement in the Texas Department of Criminal Justice - Institutional Division, probated for ten (10) years, on June 21,2009 for the offense of intoxicated assault with a vehicle causing serious bodily injury. On March 12, 2015, after a hearing, the Court found Appellant guilty of violating his probation, revoke Appellant's community supervision, and sentenced him to ten ( 10) years confinement in the Texas Department of Criminal Justice- Institutional Division. II. The Statement of Facts has been filed with the Court. III. The deadline for filing the Appellant's brief is August 10, 2015. The undersigned attorney would show the Court that he has insufficient time within which to file the brief by the deadline of August 10, 2015. Of the thirty (30) working days between June 25,2015 and August 10,2015, the undersigned attorney is in hearings, trials, and mediations on twenty-two (22) of those days. IV. The undersigned counsel would respectfully request that the Court grant an extension of an additional twenty-one (21) days' time to file the appellate brief. WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays the Court grant this motion for extension of time to file the appellate brief. Respectfully submitted, Is/ KirkHawkins KIRK HAWKINS P.O. BOX 3645 SAN ANGELO, TEXAS 76902 325/658-5585 STATE BAR NO. 09250400 E-Mail: kirkhawkinslaw@gmail.com CERTIFICATE OF CONFERENCE I hereby certify that I communicated with Mr. Jason Ferguson, Assistant District Attorney, via email on August 5, 2015, who has no objection to this Motion for Extension of Time to File Brief. Is/ KirkHawkins Kirk Hawkins CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has this 5th day of August, 2015, been delivered to Mr. Jason Ferguson, Assistant District Attorney, 124 West Beauregard, San Angelo, Texas 76903. Is/ Kirk Hawkins Kirk Hawkins