ACCEPTED
03-14-00579-CR
3642299
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/5/2015 1:49:03 AM
JEFFREY D. KYLE
CLERK
NO. 03-14-00579-CR
PERRY LEE PENNING, § IN THE THIRD COURTFILED IN
3rd COURT OF APPEALS
Appellant § AUSTIN, TEXAS
vs. § OF APPEALS AT1/5/2015 1:49:03 AM
§ JEFFREY D. KYLE
THE STATE OF TEXAS, § AUSTIN, TEXAS Clerk
Appellee §
SECOND MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
Comes Now, Appellant, Perry Lee Penning, and files this Motion for
Extension of Time to File Appellant’s Brief, pursuant to T.R.A.P. Rule 38.6(d),
and would show:
I.
Appellant’s brief was due on January 2, 2015. Appellant requests an
extension of twenty-eight (28) days to file his brief. One previous extension of
time has been granted.
II.
The facts relied on to reasonably explain the need for this extension are:
1. Unexpected absence of support staff;
2. Personal illness;
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3. Reduction of hours at U.T. Law Library where the undersigned conducts
much of her legal research on nights and weekends; and
4. This extension is necessary in order to provide effective assistance of
counsel to Appellant.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court
grant an extension of twenty-eight (28) days, until January 30, 2015, in which to
file his brief.
Respectfully submitted,
/s/ Connie J. Kelley
Connie J. Kelley
Attorney for Defendant on Appeal
1108 Lavaca, #110-221
Austin, TX 78701
(512)445-4504
(512)478-2318 (fax)
warrentucker@grandecom.net
State Bar No. 11199600
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served on
Rosemary Lehmberg, Travis County District Attorney, at P.O. Box 1748, Austin,
Texas 78767 by regular mail on this 2nd day of January, 2015.
/s/ Connie J. Kelley
Connie J. Kelley
CERTIFICATE OF COMPLIANCE
This is to certify that the foregoing document is in 14 point font. The word
count is 159 words, which is in compliance with T.R.A.P. Rule 9.4.
/s/ Connie J. Kelley
Connie J. Kelley
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