ACCEPTED
03-15-00024-CR
6391092
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/6/2015 3:37:10 PM
JEFFREY D. KYLE
CLERK
No. 03-15-00024-CR
In the FILED IN
3rd COURT OF APPEALS
COURT OF APPEALS AUSTIN, TEXAS
For the 8/6/2015 3:37:10 PM
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 is due in this case on August 7, 2015.
2. Appellant seeks an extension of sixty days in which to file his brief,
making his brief due on or before October 6, 2015.
3. In the past sixty 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 briefs in the Thirteenth Court of
Appeals in Cause Numbers 13-13-00547-CR, 13-13-00548-CR, and
13-13-00549-CR, John Steen 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 filed a Motion for Bond
Pending Final Determination of Appeal in the Thirteenth Court of Appeals in
Cause Number 13-13-00172-CR, Abraham Jacob Proenza v. The State of Texas in
a case in which the Thirteenth Court of Appeals reversed Mr. Proenza’s
conviction. 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 filed one previous motion 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 October 6, 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 August 6, 2015.
__/s/ Kristen Jernigan__________________
Kristen Jernigan
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