ACCEPTED
14-15-00036-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
2/27/2015 3:53:35 PM
CHRISTOPHER PRINE
CLERK
IN THE TEXAS COURT OF APPEALS
FOURTEENTH APPELLATE DISTRICT
HOUSTON, TEXAS
FILED IN
14th COURT OF APPEALS
JUSTIN PARKER RUSSELL § HOUSTON, TEXAS
§ Cause No. 2/27/2015 3:53:35 PM
14-15-00036-CR
v. § CHRISTOPHER A. PRINE
§ Clerk
STATE OF TEXAS §
MOTION FOR EXTENSION OF TIME TO FILE APPELLATE BRIEF
TO THE HONORABLE JUSTICES OF THIS COURT:
COMES NOW JUSTIN RUSSELL, Appellant in the above-entitled and numbered
cause, by and through undersigned counsel, and respectfully moves this honorable Court
to extend the briefing deadline set in this cause. In support of the same, undersigned
would show this Court as follows:
1. Justin Russell was convicted in cause number CR2013-379 in the 433rd
Judicial District of Comal County Texas for the felony offense of Driving While
Intoxicated. Mr. Russell perfected his appeal to the Third Court of Appeals in Austin, and
the cause was transferred to this Honorable Court pursuant to a Supreme Court Transfer
Order issued December 15, 2014. Undersigned received the completed Reporter’s Record
in this cause on February 6, 2015. This Court has set March 9, 2015, as the briefing
deadline for the Appellant
2. Undersigned has worked diligently to review the Clerk’s and Reporter’s
Records in this cause and prepare Appellants legal arguments, but requires additional time
to research the legal issues raised by the record and prepare Appellant’s brief. Undersigned
is also preparing for a jury trial in County Court at Law Number Eleven of Bexar County,
Texas on Monday, March 2, 2015. Undersigned is also in the process of changing his place
of residence, and is scheduled to close on his new residence on the morning of March 2nd
before his jury trial commences. Although undersigned will continue to work diligently as
time permits next week, these professional and personal obligations make completion of the
brief by March 9th very difficult to accomplish.
3. This request for an extension of time is sought not for the purposes of delay,
but that justice may be done.
4. This is Appellant’s first motion for an extension of time.
WHEREFORE, PREMISES CONSIDERED, Appellant prays this honorable Court
to grant a 45-day extension of time to complete and file his appellate brief in this cause.
Respectfully Submitted,
/s/ John T. Hunter
John T. Hunter
State Bar No. 24077532
THE LAW OFFICE OF JOHN HUNTER
310 S. St. Mary’s Street
Suite 1840 – Tower Life Bldg.
San Antonio, Texas 78205
(210) 399-8669
(210) 568-4927 telecopier
JTH753@gmail.com
Attorney for Justin P. Russell
CERTIFICATE OF SERVICE
This certifies that on the 27th day of February 2015, a true and correct copy of the
above and foregoing document was served on the Comal County District Attorney’s Office
via facsimile to (830) 608-2008.
/s/ John T. Hunter
John T. Hunter