Troy Luther Williams v. State

ACCEPTED 03-14-00228-CR 4815234 THIRD COURT OF APPEALS AUSTIN, TEXAS 4/8/2015 4:29:19 PM JEFFREY D. KYLE CLERK IN THE THIRD COURT OF APPEALS FOR THE STATE OF TEXAS FILED IN 3rd COURT OF APPEALS TROY WILLIAMS AUSTIN, TEXAS 4/8/2015 4:29:19 PM V. NO. 3-14-00228-CR JEFFREY D. KYLE Clerk THE STATE OF TEXAS APPELLANT’S THIRD MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE THIRD COURT OF APPEALS: COMES NOW, Troy Williams, by and through his attorney of record, Linda Icenhauer-Ramirez, and files this his Third 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. Troy Williams, Cause Number D-1-DC-12-904077 in the 147th Judicial District Court of Travis County, Texas. Appellant was sentenced on April 4, 2014. II. Appellant was convicted of the offense of aggravated kidnapping and punishment was assessed at sixty (60) years. III. Appellant’s motion for new trial was filed on April 10, 2014. Notice of appeal was filed on April 10, 2014. The reporter’s record was filed on December 2, 2014, and the clerk’s record was filed on August 4, 2014. The due date for the brief is Thursday, April 9, 2015. IV. This is Appellant’s third 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 Sunday, May 24, 2015. The next working day is Monday, May 25, 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 recently filed a supplemental brief in the case of In the Matter of J.M., 03- 14-00027-CV and she is preparing for oral argument in that case on April 22, 2015. This next week she will be filing a brief in the case of State of Texas v. Brian Roland Chandler, Cause No. 03-14-00547-CR, and she is also working on a brief in the case of Levardo Cantos v. State of Texas, Cause No. 03-14-00585-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 ON APPEAL ONLY CERTIFICATE OF COMPLIANCE I hereby certify that this motion was computer generated and contains 483 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 Third Motion for Extension of Time to Brief was served by e-file to the Travis County District Attorney's Office on this the 8th day of April, 2015. /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ