Mark Fruge v. State

ACCEPTED 03-14-00722-CR 6395829 THIRD COURT OF APPEALS AUSTIN, TEXAS 8/6/2015 11:28:31 PM JEFFREY D. KYLE CLERK NO. 03-14-00722-CR MARK FRUGE * FILED IN IN THE COURT OF APPEALS 3rd COURT OF APPEALS Appellant * AUSTIN, TEXAS 8/6/2015 11:28:31 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 APPELLATE BRIEF TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW, Appellant, and files this Motion for an Extension in which to file the Appellant’s Brief. In support of this motion, appellant shows the Court the following: I. The Appellant was convicted in the District Court of Travis County, Texas of the offense of aggravated assault. Appellant was assessed life in TDCJ. II. The deadline for filing the Appellant’s Brief is July 27, 2015 and Appellant has requested three previous extensions. III. Attorney for the Appellant would further show the Court that he has been diligent in preparing Appellant’s brief in this case. Counsel has completed the brief in this case and files it with this motion for extension of time. This Court had set a No Further Extension upon counsel’s last request for extension. Counsel files this brief and motion in conformity with T.R.A.P. 26.3 and T.R.A.P. 38.6(d), and 38.8(b). Attached to this motion is Appellant’s Brief in this case. WHEREFORE, Appellant prays the Court grant this Motion and extend the deadline for filing the Appellant’s Brief to August 7, 2015. Respectfully Submitted, ARIEL PAYAN Attorney at Law 1012 Rio Grande Austin, Texas 78701 (512) 478-3900 (512) 472-4102 (fax) Arielpayan@hotmail.com /s/ Ariel Payan ARIEL PAYAN State Bar No. 00794430 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing Motion for Extension of Time to File Appellate Brief has been delivered electronically to the Criminal District Attorney of said County Texas, at scott.taliaferro@co.travis.tx.us on August 6, 2015. /s/ Ariel Payan ARIEL PAYAN State Bar No. 00794430