ACCEPTED
03-15-00284-CR
6630758
THIRD COURT OF APPEALS
AUSTIN, TEXAS
8/24/2015 5:36:48 PM
JEFFREY D. KYLE
CLERK
CAUSE NUMBER 03—15—00284—CR
EX PARTE X IN THE COURT OF APPEALS
FILED IN
3rd COURT OF APPEALS
X AUSTIN, TEXAS
X THIRD COURT OF 8/24/2015
APPEALS 5:36:48 PM
X JEFFREY D. KYLE
Clerk
LEONARD RAY BARKER X STATE OF TEXAS
APPELLANT’S SECOND 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 August 5, 2015. A
previous Motion to Extend Time was filed on July 13, 2015, and granted the
following day.
II.
The undersigned counsel needs additional time to examine the record
and complete the research necessary to complete the Appellant’s Brief.
Counsel has labored to complete the Appellant’s Brief as quickly and
diligently as possible, but other obligations to other clients have impeded
his efforts. Counsel is scheduled to begin a jury trial in the 331st District
Court of Travis County on August 31, 2015, in a matter involving one first
degree count of Aggravated Sexual Assault and two counts of Indecency
with a Child by Contact (State v. San Juan). Counsel has no reasonable
belief that the case will be resolved in any manner other than contested trial,
lasting approximately one week, and no other cases are set on the trial
docket in the 331st District Court at that time.
In light of this and other ongoing obligations and responsibilities,
counsel would hereby respectfully request the deadline be extended to
September 21, 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 Second
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 24th day of August, 2015.
_/s/ Paul M. Evans________
PAUL M. EVANS
CERTIFICATE OF COMPLIANCE
I hereby certify that the present document contains 443 words, all
contents included.
_/s/ Paul M. Evans________
PAUL M. EVANS