ACCEPTED
01-15-00134-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/15/2015 7:26:50 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00134-CR
JENNIFER LEANN WATSON § IN THE COURT OF APPEALS
FILED IN
1st COURT OF APPEALS
§ HOUSTON, TEXAS
VS. § FOR THE FIRST DISTRICT
7/15/2015 7:26:50 PM
§ CHRISTOPHER A. PRINE
THE STATE OF TEXAS § OF TEXAS Clerk
MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT OF APPEALS:
COMES NOW Jennifer Leann Watson, Appellant, by and though her
undersigned attorney of record, and files this Motion to Extend Time to File
Appellant’s brief herein, and as sufficient cause therefore shows the following
facts within the personal knowledge of Appellant’s attorney:
I.
Appellant was indicted for the felony offense of Possession With Intent to
Deliver a Controlled Substance. Appellant pled guilty and was placed on deferred
adjudication community supervision for a period of three years. The State
subsequently filed a motion to adjudicate guilt alleging that Appellant violated the
conditions of her community supervision. Appellant pled true to the motion to
adjudicate without any agreed recommendation from the State, and the trial court
found Appellant guilty and sentenced her to serve six years in prison. Appellant
filed timely written notice of appeal.
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II.
On June 17, 2015, Appellant’s attorney received notice from this Honorable
Court of Appeals that Appellant’s first motion to extend time to file Appellant’s
brief had been granted, making Appellant’s brief due on or before July 15, 2015.
III.
Appellant’s attorney hereby requests that the due date for Appellant’s brief
be extended by a period of 30 days until August 14, 2015. This is Appellant’s
second request for an extension in this matter.
IV.
The facts relied upon to reasonably explain the need for the requested
extension are as follows:
Appellant’s attorney is a solo practitioner who had a full schedule of court
appearances on pending felony cases since June 15, 2015. In addition, during this
same period Appellant’s attorney was involved in pre-trial preparations in five
pending felony trial cases, four of which were set for jury trial the week of July 6,
2015. Further, Appellant’s attorney was involved in reviewing records and
researching points of error in nine other pending direct appeals, including three
with briefs filed the week of July 6, 2015. And finally, Appellant’s attorney was
out of town on a previously scheduled family vacation for a period of two weeks.
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Given the foregoing facts, Appellant’s attorney did not have adequate time
available to properly review the appellate record, fully research potential points of
error, and draft and file an appropriate appellate brief on Appellant’s behalf by the
current due date of July 15, 2015.
WHEREFORE, ALL PREMISES CONSIDERED, Appellant prays that this
Honorable Court of Appeals will grant this motion and extend the time to file
Appellant’s brief for a period of 30 days to August 14, 2015.
Respectfully Submitted,
/s/ Randall J. Ayers
_________________________
Randall J. Ayers
Attorney for Appellant
State Bar #01465950
P.O. Box 1569
Houston, Texas 77251-1569
rjayerslaw@comcast.net (e-mail)
281-493-6333 (office)
281-493-9609 (fax)
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CERTIFICATE OF SERVICE
I certify that I served the foregoing motion on the District Attorney of Harris
County, Texas, by sending a copy to Mr. Alan Curry, Chief of the Appellate
Division, Harris County District Attorney’s Office, via electronic service to
curry_alan@dao.hctx.net on July 15, 2015.
/s/ Randall J. Ayers
_________________________
Randall J. Ayers
Attorney for Appellant
State Bar #01465950
P.O. Box 1569
Houston, Texas 77251-1569
rjayerslaw@comcast.net (e-mail)
281-493-6333 (office)
281-493-9609 (fax)
CERTIFICATE OF COMPLIANCE
Pursuant to the provisions of Rule 9(i)(3) of the Texas Rules of Appellate
Procedure I certify that this document contains 601 words.
/s/ Randall J. Ayers
_________________________
Randall J. Ayers
Attorney for Appellant
State Bar #01465950
P.O. Box 1569
Houston, Texas 77251-1569
rjayerslaw@comcast.net (e-mail)
281-493-6333 (office)
281-493-9609 (fax)
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