State v. Gerardo Jerry Ayala

January 29, 2015 IN THE STATE OF TEXAS CIRCUIT COURT OF APPEALS AUSTIN, TEXAS CASE NUMBER: 03-14-00651-CR The State Of Texas PLAINTIFF /'RECEIVED \ VS. Gerardo "Jerry" Ayala JAN 2 9 2015 DEFENDANT \ THIRD COURT OFAPPEALS, \ JEffREYD KVLE / MOTION FOR EXTENTION TO FILE A BRIEF Defendant, Gerardo "Jerry" Ayala, moves pursuant to rules of the State of Texas Civil Procedure for an Extension Of Time To File A Brief, on the grounds that he was unable to obtain an attorney within the time allotted. WHEREFORE, Defendant, Gerardo "Jerry" Ayala, is seeking legal assistance concerning this matter, but due to time limitations, Defendant has not had the opportunity to adequately consult with and retain an attorney, and for this reason requests the extension of time to respond. WHEREFORE, Defendant Gerardo"Jerry" Ayala, hereby respectfully request an extension of time of thirty (30) days to respond to Plaintiffs' Complaint. In support of his motion, Jerry states as follows: 1. On the morning of January 1, 2015, Jerry was struck by an automobile while walking to a bus stop in downtown Austin. As a result of this accident, Jerry was under 24 hour care and totally incapacitated by physical injury and hospitalization until January 12, 2015 and is still incapacitated in financial means due to a loss of work that will extend a minimum of seven weeks from the date of the accident. In support of his claims of accident and plead for relief of an Extension To File A Briefs, Jerry has entered a copy of City Of Austin Accident Report, of this event dated January 1,2015, as well as supporting documentation from Brackenridge Hospital Staff concerning his restrictions from work. CERTIFICATE OF SERVICE The undersigned certifies he has filed this document with appropriate parties and sent a copy to the Plaintiffs Attorney at his address of record on the date below. •mi NAME (print) &flft\r n\#k -D&FglQPftKjT SIGNI Date V\ IT •