Ex Parte Leslie Parker Jones

ACCEPTED 03-14-00678-CR 3906670 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/26/2015 8:40:50 PM JEFFREY D. KYLE CLERK IN THE THIRD COURT OF APPEALS FOR THE STATE OF TEXAS FILED IN 3rd COURT OF APPEALS LESLIE PARKER JONES NO. 03-14-00678-CR AUSTIN, TEXAS 1/26/2015 8:40:50 PM VS JEFFREY D. KYLE Clerk THE STATE OF TEXAS MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS: COMES NOW, Appellant, by and through his attorneys, and files this his Motion for Extension of Time to File Appellant’s Brief, pursuant to Rules 9, 10 and 38.6(d) of the Texas Rules of Appellate Procedure, and in support thereof, would show the Court the following: I. Appellant filed a writ of habeas corpus pursuant to Tex. Code Crim. Proc Art. 11.072, in Cause no. D-1-DC-08-303025, in the 331st Judicial District Court of Travis County, which was denied by the trial court without a hearing. II. Appellant timely filed his notice of appeal and designation of record. The Reporter’s Record and the Clerk’s Record have both been filed with this Court. The Court has ordered Appellant to file his brief on or before January 22, 2015, and it is late. 1 III. Appellant’s attorneys seek an additional sixty days to file this brief. Counsel was only retained on December 15, 2014, and has not yet had time to review the Reporter’s Record, which is voluminous. Counsel also have the following matters pending: 1. Ex parte Jeffcoat, No. 05-0776-1, Williamson County, Texas; 2. Upcoming trial in Comal County in State v. Adan Castaneda, Cause No. CR2011-399; 3. Two pretrial hearings in Williamson County. 2 PRAYER Wherefore, premises considered, undersigned counsel prays this Court to extend the time for filing Appellant’s brief sixty additional days from Thursday, January 22, 2015, which would make the brief due on Monday, March 23, 2015. Respectfully submitted, Keith S. Hampton, SBN # 08873230 (512) 762-6170 (mobile) hamplaw@swbell.net Cynthia L. Hampton, SBN #11937450 (512) 731-5926 (mobile) hamplaw2@gmail.com 1103 Nueces Street Austin, Texas 78701 (512) 476-8484 (512) 477-3580 Counsel for Appellant Certificate of Service: By affixing our signatures above, we hereby certify that a true copy of Appellant’s Motion for Extension of Time to File Appellant’s Brief has this day, January 26, 2015, been delivered to: Rosemary Lehmberg, District Attorney PO Box 1748 Austin, Texas 78767. 3