ACCEPTED
03-15-00318-CR
8205407
THIRD COURT OF APPEALS
AUSTIN, TEXAS
12/11/2015 3:26:59 PM
JEFFREY D. KYLE
CLERK
CAUSE NUMBER 03—15—00318—CR
FILED IN
3rd COURT OF APPEALS
JAMAAL BRADLEY X IN THE COURT OF APPEALS
AUSTIN, TEXAS
X 12/11/2015 3:26:59 PM
V. X THIRD COURT OF APPEALS
JEFFREY D. KYLE
Clerk
X
STATE OF TEXAS X STATE OF TEXAS
APPELLANT’S THIRD 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 Third 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 November 23, 2015.
A previous Motion to Extend Time was filed on September 17, 2015, and
was granted the same date. A second Motion was filed on November 2,
2015, and was granted the following date.
II.
The undersigned counsel requires more time to complete the research
of the issues presented by the instant appeal and drafting of the Appellant’s
Brief. Counsel would hereby respectfully request the deadline be extended
to January 8, 2016.
Counsel had anticipated that he would be able to complete the
Appellant’s Brief in the period falling between November 2 and November
23—the date of the previous deadline and the new deadline requested in
Counsel’s previous Motion to Extend, respectively—but personal health
issues hampered his ability to perform the labor needed to complete the task
at that time, and the resumption of everyday court dockets after the
Thanksgiving holiday has severely curtailed his ability to devote attention to
the instant matter.
The issues involved in the instant appeal are not complex, and
Counsel anticipates he can easily tender a completed Appellant’s Bried by
no later than January 8, 2016.
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 Third
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. 11th Street, Austin,
TX, 78701—on this the 11th day of December, 2015.
_/s/ Paul M. Evans________
PAUL M. EVANS
CERTIFICATE OF COMPLIANCE
I hereby certify that the present document contains 456 words, all
contents included.
_/s/ Paul M. Evans________
PAUL M. EVANS