ACCEPTED
03-15-00281-CR
6378176
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/6/2015 8:39:01 AM
JEFFREY D. KYLE
No. 03-15-00281-CR CLERK
PEDRO P. MORALES, ) COURT OF APPEALS, THIRD
Appellant ) FILED IN
3rd COURT OF APPEALS
) AUSTIN, TEXAS
VS. ) SUPREME JUDICIAL DISTRICT
8/6/2015 8:39:01 AM
) JEFFREY D. KYLE
STATE OF TEXAS, ) Clerk
Appellee ) AUSTIN, TEXAS
APPELLANT'S SECOND MOTION FOR
EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Appellant, by and through his attorney of record, and
respectfully files this his Second Motion for Extension of Time to File Brief and
requests this extension of time to file his appellate brief in this cause herein, and for
cause would show the Court the following:
I.
The Appellant, PEDRO P. MORALES, was sentenced in Cause number C-1 0-
0321-SB, in the 3401h District Court of Tom Green County, Texas, to ten (10) years
confinement in the Texas Department of Criminal Justice - Institutional Division,
probated for ten (10) years, on June 21,2009 for the offense of intoxicated assault with
a vehicle causing serious bodily injury. On March 12, 2015, after a hearing, the Court
found Appellant guilty of violating his probation, revoke Appellant's community
supervision, and sentenced him to ten ( 10) years confinement in the Texas Department
of Criminal Justice- Institutional Division.
II.
The Statement of Facts has been filed with the Court.
III.
The deadline for filing the Appellant's brief is August 10, 2015. The
undersigned attorney would show the Court that he has insufficient time within which
to file the brief by the deadline of August 10, 2015. Of the thirty (30) working days
between June 25,2015 and August 10,2015, the undersigned attorney is in hearings,
trials, and mediations on twenty-two (22) of those days.
IV.
The undersigned counsel would respectfully request that the Court grant an
extension of an additional twenty-one (21) days' time to file the appellate brief.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays
the Court grant this motion for extension of time to file the appellate brief.
Respectfully submitted,
Is/ KirkHawkins
KIRK HAWKINS
P.O. BOX 3645
SAN ANGELO, TEXAS 76902
325/658-5585
STATE BAR NO. 09250400
E-Mail: kirkhawkinslaw@gmail.com
CERTIFICATE OF CONFERENCE
I hereby certify that I communicated with Mr. Jason Ferguson, Assistant
District Attorney, via email on August 5, 2015, who has no objection to this Motion for
Extension of Time to File Brief.
Is/ KirkHawkins
Kirk Hawkins
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has this 5th
day of August, 2015, been delivered to Mr. Jason Ferguson, Assistant District
Attorney, 124 West Beauregard, San Angelo, Texas 76903.
Is/ Kirk Hawkins
Kirk Hawkins