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