ACCEPTED
03-14-00228-CR
4241543
THIRD COURT OF APPEALS
AUSTIN, TEXAS
2/23/2015 8:05:07 AM
JEFFREY D. KYLE
CLERK
IN THE THIRD COURT OF APPEALS
FOR THE STATE OF TEXAS
FILED IN
3rd COURT OF APPEALS
TROY WILLIAMS AUSTIN, TEXAS
2/23/2015 8:05:07 AM
V. NO. 3-14-00228-CR
JEFFREY D. KYLE
Clerk
THE STATE OF TEXAS
APPELLANT’S SECOND MOTION FOR
EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE THIRD COURT OF APPEALS:
COMES NOW, Troy Williams, by and through his attorney of record, Linda
Icenhauer-Ramirez, and files this his Second 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. Troy
Williams, Cause Number D-1-DC-12-904077 in the 147th Judicial District Court of
Travis County, Texas. Appellant was sentenced on April 4, 2014.
II.
Appellant was convicted of the offense of aggravated kidnapping and punishment
was assessed at sixty (60) years.
III.
Appellant’s motion for new trial was filed on April 10, 2014. Notice of appeal
was filed on April 10, 2014. The reporter’s record was filed on December 2, 2014, and
the clerk’s record was filed on August 4, 2014. The due date for the brief is Monday,
February 23, 2015.
IV.
This is Appellant’s second motion for extension of time to file his brief.
Appellant respectfully requests a forty-five day extension of time to file the brief, which
would make such brief due on Thursday, April 9, 2015.
V.
The undersigned attorney has begun work on this case but has been unable to
complete the brief due to necessary work needed to be completed on several other appeal
cases and due to her busy schedule in both the district and county courts of Travis,
Williamson and Hays Counties. She is currently in the process of finishing up a brief in
the case of Robert Ritz v. State of Texas, Cause No. 03-14-00403-CR which is due
March 19, 2015. In addition she has a supplemental brief due on March 3, 2015 in the
case of In the Matter of J.M., 03-14-00027-CV. She is also working on briefs in other
cases including State of Texas v. Brian Roland Chandler, Cause No. 03-14-00547-CR,
which is due on March 13, 2015 and Levardo Cantos v. State of Texas, Cause No. 03-14-
00585-CR. 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 487 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 Second Motion for Extension of Time to Brief was served by e-file to
the Travis County District Attorney's Office on this the 23rd day of February, 2015.
/s/ Linda Icenhauer-Ramirez
LINDA ICENHAUER-RAMIREZ