Leovardo Cantos v. State

ACCEPTED 03-14-00585-CR 4813868 THIRD COURT OF APPEALS AUSTIN, TEXAS 4/8/2015 3:59:02 PM JEFFREY D. KYLE CLERK IN THE THIRD COURT OF APPEALS FOR THE STATE OF TEXAS FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS LEVARDO CANTOS 4/8/2015 3:59:02 PM JEFFREY D. KYLE V. NO. Clerk 3-14-00585-CR THE STATE OF TEXAS APPELLANT’S SECOND 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 Second 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 Thursday, April 9, 2015. IV. This is Appellant’s second 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 briefs in the cases of 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 ON APPEAL ONLY CERTIFICATE OF COMPLIANCE I hereby certify that this motion was computer generated and contains 498 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 Second 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 8th day of April, 2015. /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ