ACCEPTED
03-15-00263-CR
7232593
THIRD COURT OF APPEALS
AUSTIN, TEXAS
10/5/2015 3:09:23 PM
JEFFREY D. KYLE
CLERK
No. 03-15-00263-CR
In the FILED IN
3rd COURT OF APPEALS
COURT OF APPEALS AUSTIN, TEXAS
For the 10/5/2015 3:09:23 PM
THIRD SUPREME JUDICIAL DISTRICT JEFFREY D. KYLE
at Austin Clerk
______________________________________
On Appeal from the 264th Judicial District Court of
Bell County, Texas
Cause Number 73061
______________________________________
JOHN LEE BOWMAN, 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, John Lee Bowman, 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 October 2, 2015.
2. Appellant seeks an extension of sixty days in which to file his brief,
making his brief due on or before December 1, 2015.
3. In the past thirty days, the undersigned was counsel of record in the
two-week murder trial of The State of Texas v. Daniel Willis, No.
15,605 in the 21st District Court of Bastrop County. Additionally, in
the past thirty days, the undersigned has filed a brief in the First Court
of Appeals in Cause Number 01-14-01023-CR, Sean Michael
McGuire v. The State of Texas. The undersigned also filed a brief
in the Third Court of Appeals in Cause Number 03-15-00024-CR,
Steven Anthony Roe v. The State of Texas. Further, on September 9,
2015, the undersigned was the attorney of record in a contested
hearing in the 434th District Court of Fort Bend County in the Capital
Murder case of Cornelius Harper v. The State of Texas, No.
01-14-00641-CR. Finally, the undersigned has undertaken the tasks
associated with a solo practice. Consequently, the undersigned
respectfully requests that the Court grant Appellant the additional
time.
4. The undersigned has not filed any previous motions for extension of
time in this case.
5. 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 December 1, 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) 931-3650 (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 Bell
County District Attorney’s Office, 1200 Huey Road, Belton, Texas 76513 on
October 5, 2015.
__/s/ Kristen Jernigan__________________
Kristen Jernigan
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