Jim Jack Thompson, III v. State

ACCEPTED 03-14-00371-CR 3785308 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/15/2015 2:58:58 PM JEFFREY D. KYLE CLERK IN THE COURT OF APPEALS THIRD DISTRICT OF TEXAS FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 1/15/2015 2:58:58 PM JIM JACK THOMPSON III § JEFFREY D. KYLE Clerk v. § NUMBER 03-14-00371-CR THE STATE OF TEXAS § MOTION TO EXTEND TIME FOR FILING APPELLANT’S BRIEF Pursuant to Rules 38.6(d) and 10.5(b), Texas Rules of Appellate Procedure, Appellant respectfully moves for an extension of time to file appellant’s brief herein, and in support of said motion would show the following: I. The original deadline for the filing of appellant’s brief is JANUARY 15, 2015. II. Appellant’s seeks a 60 days extension of time for filing appellant’s brief, i.e. to MARCH 16, 2015. III. No previous extension of time to file appellant’s brief has been sought or granted. IV. The facts relied upon to reasonably explain the need for an extension are as follows: 1. On December 4, 2014, counsel for appellant was notified that the original dearline for filing appellant;s brief is January 15, 2015. . 2. Since December 4, 2014, rhe Christmas and New Year holiday season has occurred. 3. The appellate record in thia case is voluminous and complicated. The Reporter’s record consists of 13 volumes. At leasr 124 exhibits were admitted at trial. The Cllerk’s Record consists of 176 pages. 4. Since December 4, 2014, counsel for appellant has had numerous court appearances in District Courts and County Courts at Law in Williamson County, Travis County, and Burnet County, including a 4 days jury trial from December 8, 2014 to December 11, 2014, a contested bond hearing in a felony case, several trial settings in cases which did not actually go to trial but required counsel to spend time preparing for trial. 5. Counsel has also spent time on and appeal in a civil case in which the bries is due Febtruary 17, 2015. WHEREFORE, appellant prays that this Motion For Extension of Time to File Appellant’s Brief be granted and that the deadline for filing appellant’s brief be extended to MARCH 16, 2015. RESPECTFULLY SUBMITTED /s/ Ray Bass ________________________ RAY BASS, ATTORNEY SBN 01884000 120 WEST 8TH STREET GEORGETOWN, TEXAS 78626 TEL. 512-863-8788 FAX 512-869-5090 ATTORNEY FOR APPELLANT CERTIFICATE OF SERVICE A copy of the foregoing Motion For Extension Of Time To File Appellant’s Brief was served on JANUARY 14, 2015, in compliance with Rule 9.5, Texas Rules of Appellate Procedure and in compliance with Third Court of Appeals Local Rule 3(c), on MR. JOHN PREZAS, ASSISTANT DISTRICT ATTORNEY, WILLIAMSON COUNTY, TEXAS, 405 Martin Luther King, Box 1, Georgetown, Texas 78626. /s/ Ray Bass ___________________ RAY BASS CERTIFICATE OF CONFERENCE On January 14 2015, the below signed attorney for appellant conference with Mr. John Prezas, Assistant Ditrict Attorney for Williamson County, Appellate Attorney, regarding this Motion For Extention Of Time to File Appellant’s Brief. Mr. Prezas authorized counsel for appellant to represent to the Court the the State of Texas has no objection to the Court granting the motion. /s/ Ray Bass ___________________ RAY BASS IN THE COURT OF APPEALS THIRD DISTRICT OF TEXAS JIM JACK THOMPSON III § v. § NUMBER 03-14-00371-CR THE STATE OF TEXAS § ORDER ON APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF On this ____ day of ____________________, 2015, came on to be considered the Motion For Extension Of Time To File Appellant’s Brief; and the court, having considered said motion, finds that it should be and is hereby GRANTED. It is, therefore, ordered that Appellant shall have until MARCH 16, 2015, to file appellant’s brief herein. __________________________________ Justice, Third Court Of Appeals