ACCEPTED
03-15-00490-CR
7730564
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/9/2015 8:13:14 AM
JEFFREY D. KYLE
CLERK
No. 03-15-00490-CR & 03-15-00491-CR
ERNEST PEREZ ) IN COURT OF APPEALS
FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
V. ) FOR THE
11/9/2015 THIRD
8:13:14 AM
JEFFREY D. KYLE
THE STATE OF TEXAS ) JUDICIAL DISTRICTClerkOF TEXAS
APPELLANT’S FIRST MOTION TO
EXTEND TIME FOR FILING BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW, Ernest Perez, Appellant, through counsel, Ken Mahaffey, and
respectfully moves to extend the time for filing the Appellant’s Brief in the above
styled and numbered cause. In support thereof, Appellant would show the Court the
following:
1. JUDGMENT OF CONVICTION. The judgment being appealed was
imposed in the 274th District Court of Hays County on July 6, 2015. Appellant was
convicted of Unlawful Possession of a Firearm by a Felon and Possession of
Methamphetamine more than 4 grams but less than 200 grams.
2. APPELLANT IN CUSTODY. Appellant was sentenced to 30 years and is
currently serving that sentence.
3. DATE BRIEF DUE. Appellant’s brief is due on November 9, 2015.
4. FIRST MOTION FOR EXTENSION. This is the first motion for extension
of time to file a brief filed by either party.
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5. REASON FOR EXTENSION. Counsel has been required to work on other
appellate matters during the last thirty days. These are identified as follows:
a. Preparation of Motion for Rehearing in Arteaga v. State, No. 13-13-00612-
CR & 13-13-00613-CR;
b. Preparation of a Petition for Discretionary Review in Manuel v. State,
01-14-00107-CR.
6. DURATION OF EXTENSION SOUGHT. Appellant respectfully requests
this Court grant an extension of time for thirty (30) days to file its brief in this cause.
7. EXTENSION REASONABLE. An extension of time would be reasonable
because it will facilitate the proper research and briefing of the issues in this cause.
PRAYER FOR RELIEF
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully moves to
extend the time for filing the Appellant’s Brief in this cause by thirty (30) days.
Respectfully Submitted,
Ken Mahaffey
Counsel for Appellant
P.O. Box 684585
Austin, Texas 78768
(512) 444-6557
St. Bar. No. 12830050
Ken Mahaffey@yahoo.com
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CERTIFICATE OF SERVICE
The above signature certifies that on November 6, 2015, this document was sent
by electronic service to the Hays County D.A.’s Office and by mail to Ernest Perez,
02016895, 295 I.H. 45 North, Huntsville, TX 77320-8443.
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