Teran Pennick v. State

ACCEPTED 03-14-00334-CR 6494309 THIRD COURT OF APPEALS AUSTIN, TEXAS 8/14/2015 5:09:32 AM JEFFREY D. KYLE CLERK CAUSE NO. 03-14-00334-CR TERAN PENNICK § IN THE THIRD FILED IN § 3rd COURT OF APPEALS V. § COURT OF APPEALSAUSTIN, TEXAS 8/14/2015 5:09:32 AM § JEFFREY D. KYLE STATE OF TEXAS § OF THE STATE OF TEXAS Clerk SECOND MOTION TO EXTEND DEADLINE FOR FILING APPELLANT’S BRIEF TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW, Teran Pennick, the Appellant, in the above styled and numbered cause, and files this motion for an extension to September 17, 2015, to file the appellate brief. In support of this motion, appellant shows the following: I. The appellant was convicted in the County Court at Law No. 6 of Travis County, Texas, in Cause Number C1CR13200027 styled State of Texas vs. Teran Pennick. The appellant pled not guilty, and had a jury trial. At the conclusion of the trial, appellant was found guilty and sentenced to 1 year in the Travis County Jail, probated for 2 years. A timely notice of appeal was filed in this case. The appellant's brief is due August 17, 2015. II. The reason for the extension of the deadline to file the appellant’s brief is based on the following: Appellant's counsel is in the process of moving from the central Texas area to the Dallas/Fort Worth area due to an employment opportunity for his spouse. The opportunity arose very suddenly, and appellant's counsel needs more time to fully and adequately brief the case in this matter due to the move. For these reasons, counsel moves that the deadline for the brief be extended until September 17, 2015. RESPECTFULLY SUBMITTED, /s/ David W. Crawford David W. Crawford State Bar No. 24031601 Crawford and Cruz PLLC P.O. Box 686 Austin, Texas 78759 Telephone (512) 795-2000 Telefacsimile (512) 237-7792 Email: dcrawford@crawfordcruz.com Attorney for Appellant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing instrument has been furnished to the Attorney for the State presently assigned to this case, via fax. Date: September 17, 2015 /s/ David W. Crawford Attorney for Appellant CAUSE NO. 03-14-00334-CR TERAN PENNICK § IN THE THIRD § V. § COURT OF APPEALS § STATE OF TEXAS § OF THE STATE OF TEXAS ORDER On this day of ______________, 201___, came to be heard Appellant’s Motion for Extension of Time to File Appellant’s Brief, and it appears to the court that this motion should be: _________ GRANTED _________ DENIED IT IS THEREFORE ORDERED that the time for filing the appellant’s brief in Cause No. 03-14-00334-CR ____________ be extended to _______________, 201__. SIGNED and ENTERED this __ day of ____________, 201__. __________________________ JUDGE PRESIDING