ACCEPTED
03-14-00585-CR
4241412
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/23/2015 6:59:59 AM
JEFFREY D. KYLE
CLERK
IN THE THIRD COURT OF APPEALS
FOR THE STATE OF TEXAS
FILED IN
3rd COURT OF APPEALS
LEVARDO CANTOS AUSTIN, TEXAS
2/23/2015 6:59:59 AM
V. NO. 3-14-00585-CR
JEFFREY D. KYLE
Clerk
THE STATE OF TEXAS
APPELLANT’S FIRST MOTION FOR
EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE THIRD COURT OF APPEALS:
COMES NOW, Leovardo Cantos, by and through his attorney of record, Linda
Icenhauer-Ramirez, and files this his First Motion for Extension of Time to Brief and in
support thereof, would show the Court the following:
I.
That the above-styled and numbered cause is styled The State of Texas v. Levardo
Cantos, Cause Number 13-2081-K277 in the 277th Judicial District Court of Travis
County, Texas. Appellant was sentenced on August 11, 2014.
II.
Appellant was convicted of the offense of aggravated assault with serious bodily
injury and punishment was assessed at fifteen (15) years.
III.
Appellant’s motion for new trial was filed on September 10, 2014. Notice of
appeal was filed on September 10, 2014. The reporter’s record was filed on January 15,
2015, and the clerk’s record was filed on January 15, 2015. The exhibits were filed on
January 23, 2015. The due date for the brief is Monday, February 23, 2015.
IV.
This is Appellant’s first motion for extension of time to file his brief. Appellant
respectfully requests a forty-five day extension of time to file the brief, which would
make such brief due on Thursday, April 9, 2015.
V.
The undersigned attorney has begun work on this case but has been unable to
complete the brief due to necessary work needed to be completed on several other appeal
cases and due to her busy schedule in both the district and county courts of Travis,
Williamson and Hays Counties. She is currently in the process of finishing up a brief in
the case of Robert Ritz v. State of Texas, Cause No. 03-14-00403-CR which is due
March 19, 2015. In addition she has a supplemental brief due on March 3, 2015 in the
case of In the Matter of J.M., 03-14-00027-CV. She is also working on briefs in other
cases including State of Texas v. Brian Roland Chandler, Cause No. 03-14-00547-CR,
which is due on March 13, 2015 and Troy Luther Williams v. State of Texas, Cause Nos.
03-14-00228-CR and 03-14-00229-CR. She asks that this extension be granted so that
she may effectively represent Appellant and so that justice may be done in this case.
Respectfully Submitted
/s/ Linda Icenhauer-Ramirez
LINDA ICENHAUER-RAMIREZ
Attorney at Law
1103 Nueces
Austin, Texas 78701
(512) 477-7991
FAX #: (512) 477-3580
SBN: 10382944
EMAIL: ljir@aol.com
ATTORNEY FOR APPELLANT
CERTIFICATE OF COMPLIANCE
I hereby certify that this motion was computer generated and contains 502 words,
as calculated by the word count function on my computer.
/s/ Linda Icenhauer-Ramirez
LINDA ICENHAUER-RAMIREZ
CERTIFICATE OF SERVICE
I, Linda Icenhauer-Ramirez, hereby certify that a true and correct copy of the
foregoing Appellant’s First Motion for Extension of Time to Brief was served by e-file to
John Prezas of the Williamson County District Attorney's Office on this the 23rd day of
February, 2015.
/s/ Linda Icenhauer-Ramirez
LINDA ICENHAUER-RAMIREZ