ACCEPTED
03-15-00024-CR
5653761
THIRD COURT OF APPEALS
AUSTIN, TEXAS
6/12/2015 11:13:16 AM
JEFFREY D. KYLE
CLERK
No. 03-15-00024-CR
In the FILED IN
3rd COURT OF APPEALS
COURT OF APPEALS AUSTIN, TEXAS
For the 6/12/2015 11:13:16 AM
THIRD SUPREME JUDICIAL DISTRICT JEFFREY D. KYLE
at Austin Clerk
______________________________________
On Appeal from the 368th Judicial District Court of
Williamson County, Texas
Cause Number 13-0686-K277
______________________________________
STEVEN ROE, 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, Steven Roe, 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 8, 2015.
2. Appellant seeks an extension of sixty days in which to file his brief,
making his brief due on or before August 7, 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 Seventh Court of
Appeals in Cause Number 07-15-00016-CR, Lawrence Williams Pena v. The State
of Texas. The undersigned 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 is currently drafting a brief in the Cause Number 01-14-00641-CR,
Cornelius Milan Harper v. The State of Texas, which is a capital murder case in
which the record consists of seventy-one volumes. Further, the undersigned was
counsel of record in a hearing on an Application for Writ of Habeas Corpus based
on Double Jeopardy Grounds 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 7, 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 June 12, 2015.
__/s/ Kristen Jernigan__________________
Kristen Jernigan
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