ACCEPTED
03-15-00068-CR
4902952
THIRD COURT OF APPEALS
AUSTIN, TEXAS
4/15/2015 3:16:41 PM
JEFFREY D. KYLE
CLERK
Cause No. - -- --
IN THE THRID COURT OF APPEALS FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
KARL STAHMANN
4/15/2015 3:16:41 PM
Appellant § JEFFREY D. KYLE
§ Clerk
v. § 03 -15-00068-CR
§
§
THE STATE OF TEXAS §
APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUDGES OF THE THIRD COURT OF APPEALS:
COMES NOW APPELLANT, KARL STAHMANN, by and through his
undersigned counsel, and pursuant to Rule 10.5(b) of the Texas Rules of Appellate
Procedure, requests an extension of time to file appellant's brief. In support of this
motion, Appellant submits the following:
I.
The deadline for filing Appellant's Brief is March 30, 2015. T.R.A.P. 4.1(a).
II.
Appellant requests an extension of sixty (60) days in which to file his Appellant's
Brief. T.R.A.P. 68.2(c).
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III.
Undersigned counsel was actively preparing for a jury trial, namely: The State of
Texas v. Xavier Harper (CR-14-0270). Counsel was in a jury trial on March 8-13, 2015
in The State of Texas v. Audrina Torres (C-1-CR-14-211696). Undersigned counsel was
also actively in a Motion to Suppress Hearing on three separate occasions for The State of
Texas v. Christi Lane (D-1-DC-13-205887, D-1-DC-13-302070 and D-1-DC-14-300739).
PRAYER
Wherefore, premises considered, undersigned counsel prays for this Court to
extend the time for filing Appellant's brief as sixty days from April 15, 2015, which
would make the brief due on Friday, June 12, 2015.
Respectfully submitted,
CHARLES F. BAIRD
SBN #00000065
BAIRD FARRELLY, PLLC
2312 Western Trails Blvd, Suite 102-A
Austin, Texas 78745
Tel: 512-804-5911
Fax: 512-804-5919
Email: jcfbaird@gmail.com
ATTORNEY FOR APPELLANT
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this Motion was provided to the
Comal County District Attorney and the State Prosecuting Attorney on April 15, 2015,
via fax at (830) 608-2008.
CHARLES F. BAIRD
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