ACCEPTED
03-15-00222-CR
5966134
THIRD COURT OF APPEALS
AUSTIN, TEXAS
7/7/2015 3:33:41 PM
JEFFREY D. KYLE
CLERK
No. 03-15-000222-CR
In the FILED IN
3rd COURT OF APPEALS
COURT OF APPEALS AUSTIN, TEXAS
For the 7/7/2015 3:33:41 PM
THIRD SUPREME JUDICIAL DISTRICT JEFFREY D. KYLE
at Austin Clerk
______________________________________
On Appeal from the 277th Judicial District Court of
Williamson County, Texas
Cause Number 13-1923-K277
______________________________________
MONTE KEN ROSS, Appellant
v.
THE STATE OF TEXAS, Appellee
_____________________________________
APPELLANT’S MOTION FOR EXTENSION OF TIME
______________________________
TO THE HONORABLE JUSTICES OF THE THIRD COURT OF
APPEALS:
COMES NOW, Monte Ken Ross, Appellant herein, by and through his
attorney of record, Kristen Jernigan, and files this, his Motion for Extension of
Time. In support of said motion, Appellant would show the Court the following:
1. Appellant’s brief was due in this case on June 26, 2015.
2. Appellant seeks an extension of sixty days in which to file his brief,
making his brief due on or before August 25, 2015.
3. In the past thirty days, the undersigned has filed a brief in the
Fourteenth Court of Appeals in Cause Number 14-15-00030-CR, Miguel Macias v.
The State of Texas. The undersigned also filed a brief in the Fourth Court of
Appeals in Cause Number 04-14-00787-CR, Matthew Aranda v. The State of
Texas. In addition, the undersigned filed briefs in the Thirteenth Court of
Appeals in Cause Numbers 13-14-00547-CR; 13-14-00548-CR; and
13-14-00549-CR; John Steen v. The State of Texas. Further, the undersigned
drafted proposed Findings of Fact and Conclusions of Law based on a hearing on
an Application for Writ of Habeas Corpus in Cause Number 13-0826-K277, The
State of Texas v. Crispin Harmel, in which multiple witnesses were called and
evidence was submitted. Finally, the undersigned has made numerous court
appearances and has undertaken the tasks associated with the management of a
solo attorney practice.
4. The undersigned has not filed any previous motions for extension of
time in this case.
5. For the reasons set forth above, Appellant respectfully requests that he
be granted an extension of sixty days so that his brief in this case will now be due
on August 25, 2015.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully
requests that this Court grant his Motion for Extension of Time.
Respectfully submitted,
_______/s/__Kristen Jernigan______
KRISTEN JERNIGAN
State Bar Number 90001898
207 S. Austin Ave.
Georgetown, Texas 78626
(512) 904-0123
(512) 452-1382 (fax)
Kristen@txcrimapp.com
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the
foregoing Appellant’s Motion for Extension of Time has been emailed to John C.
Prezas, Appellate Attorney for the Williamson County District Attorney’s Office,
at jprezas@wilco.org on July 7, 2015.
__/s/ Kristen Jernigan__________________
Kristen Jernigan
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