ACCEPTED
03-12-00474-CR
4890537
THIRD COURT OF APPEALS
AUSTIN, TEXAS
4/14/2015 8:01:53 PM
JEFFREY D. KYLE
CLERK
NO. 03-12-474-CR
CHRISTINA LYONS * IN THE COURT OF APPEALS
FILED IN
3rd COURT OF APPEALS
Appellant * AUSTIN, TEXAS
4/14/2015 8:01:53 PM
VS. * OF THE THIRD JEFFREY D. KYLE
Clerk
* SUPREME JUDICIAL
* DISTRICT OF TEXAS
THE STATE OF TEXAS *
Appellee * AT AUSTIN TEXAS
MOTION FOR EXTENSION OF TIME TO FILE
MOTION FOR REHEARING AND RECONSIDERATION
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW, CHRISTINA LYONS, Appellant, and files this Motion for an
Extension in which to file a Motion for Rehearing and Reconsideration. In support
of this motion, appellant shows the Court the following:
I.
The Appellant was convicted in the District Court of Hays County, Texas of
the offense of Capital Murder. The Appellant was assessed life without the possibility
of parole
II.
The deadline for filing the Motion for rehearing and reconsideration is April,
2015 and Appellant has requested one previous extensions.
III.
Attorney for the Appellant would further show the Court that he has been
diligent in preparing a motion for rehearing in this case. Counsel has reviewed the
Court’s opinion and is drafting Appellant’s response, but will be unable to file said
response by the deadline due to a his trial and appellate docket. Counsel has had
several trial dockets in the last thirty days in multiple counties that required extensive
work up. In addition, Counsel is arguing in the Court of Criminal Appeals on a death
case on April 15 and that required more preparation than anticipated, and counsel was
unable to finish the motion.
WHEREFORE, Appellant prays the Court grant this Motion and extend the
deadline for filing a Motion for Rehearing and Reconsideration to May 15, 2015.
Respectfully Submitted,
ARIEL PAYAN
Attorney at Law
1012 Rio Grande
Austin, Texas 78701
(512) 478-3900
(512) 472-4102 (fax)
/s/ Ariel Payan
ARIEL PAYAN
State Bar No. 00794430
Arielpayan@hotmail.com
CERTIFICATE OF SERVICE
By my signature above, I hereby certify that a true and correct copy of the
above and foregoing Motion for Extension of Time to File Motion for Rehearing and
Reconsideration has been delivered to the Criminal District Attorney of said County
Texas, on April 14, 2015.