ACCEPTED
03-15-00125-CR
6854146
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/9/2015 4:30:49 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00125-CR
JAMES MONTOYA * IN THE COURT OF APPEALS
FILED IN
3rd COURT OF APPEALS
Appellant * AUSTIN, TEXAS
9/9/2015 4:30:49 PM
VS. * OF THE THIRD JEFFREY D. KYLE
Clerk
* SUPREME JUDICIAL
* DISTRICT OF TEXAS
THE STATE OF TEXAS *
Appellee * AT AUSTIN TEXAS
MOTION FOR EXTENSION OF TIME TO FILE
APPELLATE BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW, Appellant, and files this Motion for an Extension in which to
file the Appellant’s Brief. In support of this motion, appellant shows the Court the
following:
I.
The Appellant was convicted in the District Court of Hays County, Texas of
the offense of aggravated kidnaping. Appellant was sentenced to life in TDCJ.
II.
The deadline for filing the Appellant’s Brief is August 26, 2015 and Appellant
has requested no previous extensions.
III.
Attorney for the Appellant would further show the Court that he has been
diligent in preparing Appellee’s brief in this case. Due to a very busy docket counsel
is unable to complete the brief within the time frame. Counsel requests an extension
of time so that he may adequately prepare Appellant’s Brief. Counsel must complete
his investigation of the record and draft the brief.
WHEREFORE, Appellant prays the Court grant this Motion and extend the
deadline for filing the Appellant’s Brief to October 12, 2015.
Respectfully Submitted,
ARIEL PAYAN
Attorney at Law
1012 Rio Grande
Austin, Texas 78701
(512) 478-3900
(512) 472-4102 (fax)
Arielpayan@hotmail.com
/s/ Ariel Payan
ARIEL PAYAN
State Bar No. 00794430
CERTIFICATE OF SERVICE
By my signature above, I hereby certify that a true and correct copy of the
above and foregoing Motion for Extension of Time to File Appellate Brief has been
delivered to the Criminal District Attorney of said County Texas, on September 8,
2015.
James Robert Montoya, Jr. v. State
Combined Opinion