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