ACCEPTED
03-14-00530-CR
3825757
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/20/2015 12:43:48 PM
JEFFREY D. KYLE
CLERK
03-14-00530-CR
GRAHAM JAY SONNENBERG FILED
IN THE COURT OF IN
APPEALS
3rd COURT OF APPEALS
AUSTIN, TEXAS
VS. THIRD 12:43:48
1/20/2015 DISTRICT
PM
JEFFREY D. KYLE
Clerk
STATE OF TEXAS SITTING IN AUSTIN, TEXAS
MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT'S BRIEF
To the Court of Appeals, Third Supreme Judicial District:
Now comes GRAHAM JAY SONNENBERG, Appellant, by and through his
attorney of record in the above entitled and numbered cause, and files this his Motion
for Extension of Time in which to file Appellant's Brief, and would show the
following:
I.
On August 15, 2014, in the 427th District Court of Travis County, Texas in
Cause No. D-1-DC-14-904026 entitled The State of Texas v. GRAHAM JAY
SONNENBERG, the Appellant was convicted of the offenses of
COUNT ONE (alleged to have been committed on October 29, 2012),
Aggravated Assault Bodily Injury with a Deadly Weapon. Defendant
sentenced to twenty years confinement; and
COUNT TWO (alleged to have been committed on October 29, 2012),
Assault Strangulation Enhanced. Defendant was sentenced to sixteen
years confinement.
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II.
On August 15, 2014, and within the time required by the Texas Rules of
Appellate Procedure Appellant filed his written Notice of Appeal to the Court of
Appeals for the Third Supreme Judicial District of Texas.
III.
A Motion for New Trial was filed on the August 15, 2014, and was overruled
by the court by operation of law.
IV.
The Record on Appeal was timely filed and the Appellant's Brief in this case
is due to be filed not later than January 20, 2105, a date which is less than 15 days
preceding the effective filing date of this motion for extension of time.
V.
That Appellant now makes his first request for an extension of time in which
to file Appellant's Brief. The period of time requested is an additional sixty-three
(63) days, or until March 23, 2015.
VI.
The facts relied upon to reasonably explain the need for an extension of time
are as follows: the undersigned counsel is the only attorney representing Appellant
and is Court Appointed; counsel has been engaged in the preparation for and
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trial/hearing of various matters which have prevented counsel from preparing
Appellant’s Brief.
WHEREFORE, PREMISES CONSIDERED, Appellant requests this motion
for extension of time be granted and that the Court extend the time for the filing of
Appellant's Brief for a period of sixty three days or until March 23, 2015.
Respectfully Submitted,
LAW OFFICE OF DON MOREHART
316 West 12th Street, Suite 313
Austin, Texas 78701
Telephone 512-551-0404
Telecopier 512-551-0405
Don@MorehartLaw.com
ATTORNEY FOR APPELLANT
_ /s/ Don Morehart __
DON MOREHART
SBN 14423700
CERTIFICATE OF SERVICE
By my signature above/below, I hereby certify that a true and correct copy of
the above and foregoing was served upon the State’s Attorney, Travis County District
Attorney, VIA FAX to Appellate Section Fax 512-854-4206 on January 17, 2015.
_ /s/ Don Morehart __
Don Morehart
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