Norma Cisneros v. State

ACCEPTED 03-17-00317-CR 21579659 THIRD COURT OF APPEALS AUSTIN, TEXAS 1/3/2018 1:45 PM JEFFREY D. KYLE CLERK IN THE THIRD COURT OF APPEALS FOR THE STATE OF TEXAS FILED IN 3rd COURT OF APPEALS NORMA CISNEROS AUSTIN, TEXAS 1/3/2018 1:45:37 PM V. NO. 03-17-00317-CR JEFFREY D. KYLE Clerk THE STATE OF TEXAS APPELLANT’S THIRD MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE THIRD COURT OF APPEALS: COMES NOW, Norma Cisneros, by and through her attorney of record, Linda Icenhauer-Ramirez, and files this Appellant’s Third Motion for Extension of Time to Brief and in support thereof, would show the Court the following: I. That the above-styled and numbered cause is styled The State of Texas v. Norma Cisneros, Cause Number CR-14-0755 in the 22nd Judicial District Court of Hays County, Texas. Appellant was sentenced on May 9, 2017. II. Appellant was convicted of the offense of fraudulent transfer of a motor vehicle and sentenced to two years imprisonment. Appellant’s sentence was suspended and she was placed on five years community supervision. III. Appellant’s motion for new trial was filed on June 2, 2017. Notice of appeal was filed on May 10, 2017. The reporter’s record was filed on August 24, 2017. The clerk’s record was filed on September 5, 2017. The supplemental reporter’s record was filed on October 5, 2017. The due date for the brief is Wednesday, January 3, 2018. IV. This is Appellant’s third motion for extension of time to file her brief. Appellant respectfully requests a forty-five day extension of time to file the brief, which would make such brief due on Saturday, February 17, 2018. The next working day is Monday, February 19, 2018 V. The undersigned attorney has been unable to complete the brief due to necessary work that needed to be completed on several other appeal cases and due to her busy schedule in both the district and county courts of Travis County, Hays County and Williamson County. She has recently filed a brief in the case of Cuong Tran v. State of Texas, Cause No. 03-17-00155- CR. Today she is completing work on a brief in the case of Roberto Sandoval v. State of Texas, Cause No. 01-17-00531-CR, which is due tomorrow in the First Court of Appeals. Once she completes that brief, she will devote her full attention to completing the brief in this case. She asks that this extension be granted so that she may effectively represent Appellant and so that justice may be done in this case. Respectfully Submitted /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ Attorney at Law 1103 Nueces Austin, Texas 78701 (512) 477-7991 FAX #: (512) 477-3580 SBN: 10382944 EMAIL: ljir@aol.com ATTORNEY FOR APPELLANT CERTIFICATE OF COMPLIANCE I hereby certify that this motion was computer generated and contains 497 words, as calculated by the word count function on my computer. /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ CERTIFICATE OF SERVICE I, Linda Icenhauer-Ramirez, hereby certify that a true and correct copy of the foregoing Appellant’s Third Motion for Extension of Time to Brief was served by e-file to Michael McCarthy of the Hays County District Attorney's Office on this the 3rd day of January, 2018. /s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ