Joe Derek Carr v. State

ACCEPTED
03-14-00234-CR
4065029
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/8/2015 8:15:50 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00234-CR

In the February 9, 2015
COURT OF APPEALS
For the
THIRD SUPREME JUDICIAL DISTRICT
at Austin
______________________________________

On Appeal from the 167th Judicial District Court of
Travis County, Texas
Cause Number D-1-DC-11-100059
______________________________________

JOE DEREK CARR, Appellant
v.
THE STATE OF TEXAS, Appellee
_____________________________________

APPELLANT’S MOTION FOR EXTENSION OF TIME
______________________________

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF

APPEALS:

COMES NOW, Joe Derek Carr, Appellant herein, by and through his

attorney of record, Kristen Jernigan, and files this, his Motion for Extension of

Time. In support of said motion, Appellant would show the Court the following:

1. Appellant’s brief was due in this case on January 19, 2015.

2. Appellant seeks an extension of sixty days in which to file his brief,
making his brief due on or before March 19, 2015.

3. The undersigned inadvertently calendared the due date for Appellant’s
brief as February 19, 2015.

4. In the past thirty days, the undersigned has filed briefs in the First
Court of Appeals in Cause Numbers 01-14-00240-CR, Sean Michael McGuire, v.
The State of Texas; and 01-14-00241-CR, Sean Michael McGuire v. The State of
Texas. In addition, the undersigned filed a Petition for Writ of Habeas Corpus in
Cause Number 08-1623-K26, Ex parte Adam Adel Hayek. Finally, the undersigned
has made numerous court appearances and has undertaken the tasks associated
with the management of a solo attorney practice.

5. The undersigned has filed one previous motion for extension of time
in this case.

6. For the reasons set forth above, Appellant respectfully requests that he
be granted an extension of sixty days so that his brief in this case will now be due
on March 19, 2015.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully

requests that this Court grant his Motion for Extension of Time.

Respectfully submitted,

_______/s/__Kristen Jernigan______
KRISTEN JERNIGAN
State Bar Number 90001898
207 S. Austin Ave.
Georgetown, Texas 78626
(512) 904-0123
(512) 452-1382 (fax)
Kristen@txcrimapp.com
CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the

foregoing Appellant’s Motion for Extension of Time has been mailed to the Travis

County District Attorney’s Office, P.O. Box 1748, Austin, Texas, 78767, on

February 9, 2014.

__/s/ Kristen Jernigan__________________
Kristen Jernigan