Michelle Elaine Gambles v. State

ACCEPTED 03-14-00484-CR 6515999 THIRD COURT OF APPEALS AUSTIN, TEXAS 8/17/2015 8:59:03 AM JEFFREY D. KYLE CLERK NO. 03-14-00484-CR MICHELLE GAMBLES § IN THE § FILED IN 3rd COURT OF APPEALS vs. § THIRD TEXAS AUSTIN, COURT § 8/17/2015 8:59:03 AM THE STATE OF TEXAS § OF APPEALS JEFFREY D. KYLE Clerk MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes MICHELLE GAMBLES, Appellant in the above styled and numbered cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the County Court At Law of Bell County, Texas. 2. The case below was styled the STATE OF TEXAS vs. MICHELLE GAMBLES, and numbered 2Cl3-07438. 3. Appellant was convicted of Resisting Arrest or Search. 4. Appellant was assessed a sentence of6 days in jail on July 16,2014. 5. Notice of appeal was given on August 4, 2014. 6. The clerk's record was filed on September 5, 2014; the reporter's record was filed on January 9, 2015. 7. The appellate brief is presently due on May 22, 2015. 8. Appellant requests an extension of time of90 days from the present date, i.e. August 20, 2015. 9. Two extensions to file the brief have been received in this cause. 10. Defendant is not currently incarcerated. II. Appellant relies on the following facts as good cause for the requested extension: Attorney handling the appellant's brief is no longer with the firm. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this Motion To Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate. Respectfully submitted, 455 East Centr I ·' 7 ~~-------~--------- BOBBY DALE BARINA State BarNo. 0!738480 Attorney for MICHELLE GAMBLES CERTIFICATE OF SERVICE This is to certifY that on August 17, 2015, a true and correct copy of the above and foregoing document was served on the Bell County Attorney's 0 unty, by facsimile transmission to 254-933-5150. BOBBY DALE BARINA I STATE OF TEXAS § § COUNTY OF BELL § AFFIDAVIT BEFORE ME, the undersigned authority, on this day personally appeared BOBBY DALE BARINA, who after being duly sworn stated: "I am the attorney for the appellant in the above nwnbered and entitled cause. I have read the foregoing Motion To Extend Time to File A ellant's Brief and swear that all of the allegations of fact contained ther ·n are true correct." I BOBBYD Affiant / SUBSCRIBED AND SWORN TO rBE E n August 17, 2015, to certifY which witness my hand and seal of office.