Peter Ezebunwa v. State

ACCEPTED 03-14-00682-CR 5523815 THIRD COURT OF APPEALS AUSTIN, TEXAS 6/3/2015 10:55:06 AM JEFFREY D. KYLE CLERK CAUSE NO. 03-14-00682-CR PETER EZEBUNWA § IN THE THIRD COURT FILED IN Appellant, § 3rd COURT OF APPEALS § AUSTIN, TEXAS § 6/3/2015 10:55:06 AM v. § OF APPEALSJEFFREY D. KYLE Clerk § THE STATE OF TEXAS § Appellee, § STATE OF TEXAS SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES PETER EZEBUNW A, Appellant, by and through their attorney, Amber Vazquez Bode, and file this Second Motion for Extension of Time to File Appellant's Brief. In support thereof Appellant offers as follows: 1. According to the Texas Rules of Appellate Procedure Rule 38.6 Time to File Briefs: "(a) Appellant's Filing Date. Except in a habeas corpus or bail appeal, which is governed by Rule 31, an appellant must file a brief within 3 0 days-20 days in an accelerated appeal-after the later of: ( 1) The date the clerk's record was filed; or (2) The date the reporter's record was filed." 2. The Reporter's Record was filed on March 2, 2015. 3. The Clerk's record was filed on February 5, 2015. 4. The appellant's brief was due on June 5, 2015 according to Rule 38.6. 5. Appellant hereby requests an extension of 30 days due to the stated reasons. Pursuant to the Texas Rules of Appellate Procedure the Appellant has the right to request an extension of time. It states, "(d) Modifications of Filing Time. On motion complying with Rule 10.5 (b), the appellate court may extend the time for filing a brief and may postpone submission of the case. A motion to extend the time to file a brief may be filed before or after the date the brief is due. The court may also, in the interests of justice, shorten the time for filing briefs and for submission of the case." Appellant respectfully requests a brief extension of 30 days in order to receive proper research for the case. Appellant requests that the time period designated by Texas Rules of Appellate Procedure 38.6 (d) be applied and that Appellant have and extension of time to file the brief. The Appellant respectfully requests that this court GRANT the Second Motion for Extension of Time to File Appellant's Brief. Respectfully submitted, {?{v1~-lJ~~ 1!3:P Amber Vazquez State Bar No. 24039225 The Vazquez Law Firm 1004 West Ave. Austin, Texas 78701 (512) 220-8507 (telephone) ( 5 12) 480-07 60 (facsimile) atnberv@lawyers.com COUNSEL FOR APPELLANT CERTIFICATE OF SERVICE I, AMBER VAZQUEZ BODE, Attorney for Appellant, do hereby certify that a true and correct copy of the above and foregoing Second Motion for Extension of Time to File Appellant's Brief has been served electronically on June 3, 2015. v AMBER AZQUEZ BODE Attorney for Appellant - Third Court of Appeals Price Daniel Sr. Bldg. 209 West 14th Street, Room 101 Austin, Texas 78701 Ms. Ellie Klemens Court Reporter 427th Judicial District Court Blackwell-Thunnan Justice Center 509 West 11th Street-3rd Floor Austin, Texas 78701 Facsimile: (512) 854-2227 Travis County District Attorney Appellate Division 509 West 11th Street Austin, Texas 78701 Facsimile: (512) 854-9695 Travis Count~ District Clerk 509 West 11 t Street, Room 1.400 Austin, Texas 78701 Facsimile: (512) 854-4566 The Honorable Wilford Flowers 427th District Court Blackwell- Thunn~1 n Justice Center 509 West 11th Strcct Austin, Texas 78701 Facsimile: (512) 854-222 CAUSE NO. 03-14-00682-CR PETER EZEBUNWA § IN THE THIRD COURT Appellant, § § § v. § OF APPEALS § § THE STATE OF TEXAS § STATE OF TEXAS Appellee, § ORDER GU.ANTING SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF After considering the Second Motion for Extension of Time to File Appellant's Brief the Court has detennined that the motion is OF MERIT and is GRANTED/DENIED. IT IS SO ORDERED on this _ _ day of _ _ _ _, 2015. JUDGE PRESIDING