Juan Leal, Jr. v. State

ACCEPTED 03-15-00095-CR 6426266 THIRD COURT OF APPEALS AUSTIN, TEXAS 8/10/2015 2:06:57 PM JEFFREY D. KYLE CLERK CAUSE NUMBER 03—15—00095—CR FILED IN 3rd COURT OF APPEALS STATE OF TEXAS X IN THE COURT OF APPEALS AUSTIN, TEXAS X 8/10/2015 2:06:57 PM V. X THIRD COURT OF APPEALS JEFFREY D. KYLE Clerk X JUAN LEAL X STATE OF TEXAS APPELLANT’S AMENDED MOTION TO EXTEND TIME FOR FILING OF APPELLANT’S BRIEF TO THE HONORABLE COURT OF APPEALS: COMES NOW THE APPELLANT, by and through his appointed attorney of record, Paul M. Evans, in the above entitled and numbered cause, and moves this Court, to grant the Appellant’s Motion to Extend Time for Filing Appellant’s Brief, and, in support thereof, would show the Court as follows: I. Appellant’s Brief was due before this Court on July 13, 2015. No previous Motions to Extend Time have been sought. II. The undersigned counsel needs additional time to examine the record and complete the research necessary to complete the Appellant’s Brief. This Court has noted that the Reporter’s Record was filed on June 11, 2015. However, after repeated inquiries in the meantime, Counsel was not able to access these records through the Travis County District Clerk until July 14, 2015. Counsel has not had an adequate opportunity at this time to review the record. Counsel would hereby respectfully request the deadline be extended to September 4, 2015. III. This Motion is not made for purposes of delay, but so that justice might be served. WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that this Court, upon good cause shown, grant the Appellant’s Motion to Extend Time for Filing Appellant’s Brief. Respectfully submitted, Law Office of Paul M. Evans 811 Nueces Street Austin, Texas 78701 (512) 569-1418 (512) 692-8002 FAX _/s/ Paul M. Evans________ PAUL M. EVANS SBN 24038885 Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing was delivered by facsimile unto the office of the prosecuting attorney for the State of Texas—the Travis County District Attorney, mailing address P.O. Box 1748, Austin, TX, 78767, physical address 509 W. 11 th Street, Austin, TX, 78701—on this the 10th day of August, 2015. _/s/ Paul M. Evans________ PAUL M. EVANS CERTIFICATE OF COMPLIANCE I hereby certify that the present document contains 368 words, all contents included. _/s/ Paul M. Evans________ PAUL M. EVANS