Richard Lee Pollard v. State

ACCEPTED 03-14-00545-CR 3639791 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/2/2015 4:11:13 PM JEFFREY D. KYLE CLERK NO. 03-14-00545-CR FILED IN 3rd COURT OF APPEALS In The Third Court of Appeals AUSTIN, TEXAS 1/2/2015 4:11:13 PM Austin, Texas JEFFREY D. KYLE Clerk RICHARD LEE POLLARD Appellant v. THE STATE OF TEXAS, Appellee Cause no. CR6692 On Appeal from the 33rd Judicial District Court of Llano County, Llano, Texas MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE THIRD COURT OF APPEALS: Appellant, Richard Lee Pollard, pursuant to Rule 10.5 of the Texas Rules of Appellate Procedure, by and through his attorney of record, requests an extension of time to file appellant's brief, and in support thereof would show the court the following: 1_The reporter's record was filed on September 17, 201. The clerk's record was filed on October 24, 2014. 2_Under the court's briefing schedule, the appellant's brief is currently due on January 8, 2014. 3_The undersigned attorney has an extensive trial practice, both civil and criminal. Further, the undersigned counsel has numerous and regular court appearances consisting of motions to revoke and suppression hearings. Likewise, the undersigned is preparing for several jury trials which are subject to being tried within the following forty (30) days. 4_ In order to prepare a brief that will be of assistance to the Court, the undersigned seeks a 30-day extension of time to file its appellant's brief, so that the brief will be due on February 8, 2015. 5_This is the second request for an extension of time to file Appellant's brief. This extension is not sought solely for delay, but is necessary so that justice can be done. For these reasons, Appellant respectfully requests that the Court grant this motion to extend the time for filing Appellant's brief and allow that brief to be filed on or before February 8, 2015. Appellant also requests any other relief to which it may be entitled. Respectfully submitted, 111 E. Jackson Street PO Box 398 Burnet, Texas 78611 (512)756-5117 (512) 756-0164 Fax State Bar No. 05537100 Email: rdd@austin. twcbc.com CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Motion for Extension of Time to File Appellant's Brief has been hand delivered, or sent by U.S. mail, certified return receipt requested, or transmitted by telephonic transfer to the counsel for the State, Gary W. Bunyard, of the Office of the District Attorney of Llano County, P.O. Box 725, Llano, Texas 78643; on this the2!J__ day of ,Oe ~ , 2014. d/~ ~~/ RICHARD D. DAVIS CERTIFICATE OF CONFERENCE The undersigned by his signature below certifies that the District Attorney's Office of the 33RD Judicial District has been contacted and that this motion is not opposed by Appellee.