Ronnie Hue Montgomery v. State ( 2015 )

ACCEPTED
03-15-00203-CR
7896672
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/19/2015 5:55:03 AM
JEFFREY D. KYLE
CLERK
NO. 03-15-00203-CR
STATE OF TEXAS § IN THE THIRD
FILED IN
§ 3rd COURT OF APPEALS
VS. § COURT OF APPEALS AUSTIN, TEXAS
§ 11/19/2015 5:55:03 AM
RONNIE MONTGOMERY § AUSTIN, TEXAS JEFFREY D. KYLE
Clerk
SECOND MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Ronnie Montgomery., Appellant in the above styled and numbered cause,
and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6
of the Texas Rules of Appellate Procedure, and for good cause shows the following:
1. This case is on appeal from the 147th District Court of Travis County, Texas.
2. The case below was styled the STATE OF TEXAS vs. Ronnie Montgomery, and
numbered D1DC13202988.
3. Appellant was convicted of Evading Arrest with a Vehicle
4. Appellant was assessed a sentence of 5 years TDCJ, which was probated on April
8, 2015..
5. Notice of appeal was given timely and the Clerk and Reporters records have been
duly filed with the Court of Appeals..
6. The appellate brief was due on or about November 12, 2015
8. Appellant requests an extension of time of 21 days from todays date, i.e. that the
brief be due on or before December 10, 2015.
9. One prior extension to file the brief has been received in this cause.
10. Defendant is currently not incarcerated.
11. Appellant relies on the following facts as good cause for the requested extension:
Appellant’s attorney had reason to believe that a portion of the record was missing and
has been in contact with the Court Reporter.
In fact, the Court Reporter found additional transcripts which were filed with the
Court on or about November 15, 2015 with the Court.. Therefore, Appellant’s attorney needs
additional time to research the issues with regards to the additional records provided by the court.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court
grant this Motion To Extend Time to File Appellant's Brief, and for such other and further relief
as the Court may deem appropriate.
Respectfully submitted,
Rickey Jones
Attorney at Law
1910 Pacific Ave, Ste 15100
Dallas, Texas 75201
By:
Rickey Jones
State Bar No. 00787791
Attorney for Appellant
CERTIFICATE OF SERVICE
This is to certify that on November 19, 2015, a true and correct copy of the above and
foregoing document was served on the District Attorney's Office, Travis County, by facsimile
transmission.
Rickey Jones