ACCEPTED
03-14-00235-CR
4065024
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/8/2015 8:14:58 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00235-CR
In the FILED IN
3rd COURT OF APPEALS
COURT OF APPEALS AUSTIN, TEXAS
For the 2/9/2015 12:00:00 AM
THIRD SUPREME JUDICIAL DISTRICT JEFFREY D. KYLE
at Austin Clerk
______________________________________
On Appeal from the 167th Judicial District Court of
Travis County, Texas
Cause Number D-1-DC-11-902003
______________________________________
JOE DEREK CARR, 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, Joe Derek Carr, 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 January 19, 2015.
2. Appellant seeks an extension of sixty days in which to file his brief,
making his brief due on or before March 19, 2015.
3. The undersigned inadvertently calendared the due date for Appellant’s
brief as February 19, 2015.
4. In the past thirty days, the undersigned has filed briefs in the First
Court of Appeals in Cause Numbers 01-14-00240-CR, Sean Michael McGuire, v.
The State of Texas; and 01-14-00241-CR, Sean Michael McGuire v. The State of
Texas. In addition, the undersigned filed a Petition for Writ of Habeas Corpus in
Cause Number 08-1623-K26, Ex parte Adam Adel Hayek. Finally, the undersigned
has made numerous court appearances and has undertaken the tasks associated
with the management of a solo attorney practice.
5. The undersigned has filed one previous motion for extension of time
in this case.
6. 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 March 19, 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) 452-1382 (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 Travis
County District Attorney’s Office, P.O. Box 1748, Austin, Texas, 78767, on
February 9, 2014.
__/s/ Kristen Jernigan__________________
Kristen Jernigan
2