ACCEPTED
03-15-00424-CR
7436242
THIRD COURT OF APPEALS
AUSTIN, TEXAS
10/19/2015 2:43:11 PM
JEFFREY D. KYLE
CLERK
03-15-00424-CR
ADAM GUERRERO PEREZ FILED
IN THE COURT OF IN
APPEALS
3rd COURT OF APPEALS
AUSTIN, TEXAS
VS. THIRD DISTRICT
10/19/2015 2:43:11 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 Adam Guerrero Perez, 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 June 29, 2015, in the 147th District Court of Travis County, Texas in Cause
No. D1DC14202568 entitled The State of Texas v. Adam Guerrero Perez, the
Appellant was convicted of the offense of Driving While Intoxicated, 3rd Offense or
More, Enhanced, and sentenced to twenty years confinement in the Texas Department
of Criminal Justice, Institutional Division.
II.
On June 29, 2015, and within the time required by the Texas Rules of Appellate
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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 not filed.
IV.
The Record on Appeal was timely filed and the Appellant's Brief in this case
is due to be filed not later than Octo ber 21, 2015
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-one (61)
days, or until December 21, 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
trial/hearing of a variety of other matters, and has been engaged in dealing with an
active practice of court appointed cases.
WHEREFORE, PREMISES CONSIDERED, Appellant requests this motion
for extension of time be granted and that the Court extend the time for the filing of
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Appellant's Brief for a period of sixty-one (61) days, or until December 21, 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 following persons in the manner
described on October 19, 2015.
Travis County District Attorney's Office
509 West 11th Street
Austin, TX 78701
Via Fax to 512-854-4951
_ /s/ Don Morehart __
Don Morehart
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