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