ACCEPTED
03-15-00222-CR
6761839
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/2/2015 11:54:39 AM
JEFFREY D. KYLE
CLERK
No. 03-15-000222-CR
In the FILED IN
3rd COURT OF APPEALS
COURT OF APPEALS AUSTIN, TEXAS
For the 9/2/2015 11:54:39 AM
THIRD SUPREME JUDICIAL DISTRICT JEFFREY D. KYLE
at Austin Clerk
______________________________________
On Appeal from the 277th Judicial District Court of
Williamson County, Texas
Cause Number 13-1923-K277
______________________________________
MONTE KEN ROSS, 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, Monte Ken Ross, 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 was due in this case on August 25, 2015.
2. Appellant seeks an extension of sixty days in which to file his brief,
making his brief due on or before October 24, 2015.
3. In the next thirty days, the undersigned is preferentially set in a
murder trial in the 21st District Court of Bastrop County in Cause Number 15,605,
The State of Texas v. Daniel Willis. The trial is expected to last two weeks. In
addition, the undersigned is set for a hearing in the 434th District Court in Cause
Number 11-DCR-56513, The State of Texas v. Cornelius Milan Harper. This is a
capital murder case in which there are serious omissions and misstatements in the
Reporter’s Record which requires the undersigned to review eighteen volumes of
the record before September 9, 2015. Finally, the undersigned has a brief due in
the First Court of Appeals in the case of Sean McGuire v. The State of Texas, No.
01-14-00123-CR.
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 24, 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 September 2, 2015.
__/s/ Kristen Jernigan__________________
Kristen Jernigan
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