ACCEPTED
01-15-00035-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/9/2015 6:01:12 PM
CHRISTOPHER PRINE
CLERK
No.01-15-00035-CR
——————————————————————————————
FILED IN
1st COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
1st DISTRICT OF TEXAS 6/9/2015 6:01:12 PM
HOUSTON, TEXAS CHRISTOPHER A. PRINE
—————————————————————————————— Clerk
THIRD MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S
INITIAL BRIEF
CHAD LEE BRUBAKER
APPELLANT
VS.
THE STATE OF TEXAS
APPELLEE
Appealed from the 411th Judicial District Court
of Polk County, Texas
JENNIFER L. BERGMAN
State Bar No: 24064889
P.O. Box 1492
709 S. Washington Ave.
Cleveland, Texas 77328-1676
Telephone No.: (281) 592-2422
Facsimile No.: (281) 592-7136
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APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S INITIAL BRIEF
___________________________________________________________
TO THE HONORABLE COURT OF APPEALS:
Appellant, under Texas Rules of Appellate Procedure, 38.6(b), respectfully
requests the Court to extend the time to file Appellant’s Initial Brief and would
show the following:
1. Chad Lee Brubaker is the Appellant. The State of Texas is the
Appellee.
2. Appellant’s Initial Brief in this matter was due June 8, 2015.
3. Jennifer L. Bergman, was appointed to represent Appellant in his
appeal.
4. On June 8, 2015, counsel for Appellant had serious computer issues
and was unable to file Appellant’s Initial Brief. Thus counsel was
only able to file Appellant’s Initial Brief on June 9, 2015, after the
computer issues were resolved. Counsel is filing Appellant’s Initial
Brief contemporaneously with this Motion for Extension of Time to
File.
5. Therefore, Appellant requests this Honorable Court to grant Appellant
a three (3) day extension of time for the filing of Appellant’s Initial
Brief.
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6. Appellant’s counsel was unable to speak with Kari Allen, an assistant
District Attorney with the Polk County District Attorney’s Office to
secure a response as to whether she opposed or did not oppose this
extension of time.
7. This is Appellant’s third request for an extension of time to file
Appellant’s Initial Brief in this matter, making this the third request
that has been made by Appellant.
8. Appellant requests this extension of time not for the purpose of delay,
but so that justice can be done and the matter properly presented to
this Honorable Court.
Respectfully submitted,
/s/ Jennifer L. Bergman
JENNIFER L. BERGMAN
State Bar No: 24064889
P.O. Box 1492
709 S. Washington Ave.
Cleveland, Texas 77328-1676
Telephone No.: (281) 592-2422
Facsimile No.: (281) 592-7136
Attorney for Appellant
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CERTIFICATE OF CONFERENCE
& CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been sent to
the Polk County District Attorney’s office on this the 9th day of June, 2015, via fax
936-327-6875.
/s/ Jennifer L. Bergman
Jennifer L. Bergman
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