ACCEPTED
03-15-00432-CR
7751028
THIRD COURT OF APPEALS
AUSTIN, TEXAS
11/9/2015 4:17:17 PM
JEFFREY D. KYLE
CLERK
IN THE THIRD COURT OF APPEALS
FOR THE STATE OF TEXAS
FILED IN
3rd COURT OF APPEALS
CHRISTOPHER GERMAN REYES AUSTIN, TEXAS
11/9/2015 4:17:17 PM
V. NO. 3-15-00432-CR
JEFFREY D. KYLE
Clerk
THE STATE OF TEXAS
APPELLANT’S FIRST MOTION FOR
EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE THIRD COURT OF APPEALS:
COMES NOW, Christopher German Reyes, by and through his attorney of
record, Linda Icenhauer-Ramirez, and files this his First Motion for Extension of Time to
Brief and in support thereof, would show the Court the following:
I.
That the above-styled and numbered cause is styled The State of Texas v.
Christopher German Reyes, Cause Number D-1-DC-14-301140 in the 427th Judicial
District Court of Travis County, Texas. Appellant was sentenced on June 12, 2015.
II.
Appellant was convicted of the offense of aggravated sexual assault of a child and
punishment was assessed at thirty (30) years.
III.
Appellant’s motion for new trial was filed on June 12, 2015. Notice of appeal
was filed on July 8, 2015. The reporter’s record was filed on September 24, 2015, and
the clerk’s record was filed on October 9, 2015. The due date for the brief is Monday,
November 9, 2015.
IV.
This is Appellant’s first motion for extension of time to file his brief. Appellant
respectfully requests a forty day extension of time to file the brief, which would make
such brief due on Saturday, December 19, 2015. The next working day is Monday,
December 21, 2015.
V.
The undersigned attorney has read the record in this case and has begun drafting
the brief but has been unable to complete the brief due to necessary work needed to be
completed on several other appeal cases and due to her busy schedule in both the district
and county courts of Travis and Williamson Counties. She asks that this extension be
granted so that she may effectively represent Appellant and so that justice may be done in
this case.
Respectfully Submitted
/s/ Linda Icenhauer-Ramirez
LINDA ICENHAUER-RAMIREZ
Attorney at Law
1103 Nueces
Austin, Texas 78701
(512) 477-7991
FAX #: (512) 477-3580
SBN: 10382944
EMAIL: ljir@aol.com
ATTORNEY FOR APPELLANT
CERTIFICATE OF COMPLIANCE
I hereby certify that this motion was computer generated and contains 421 words,
as calculated by the word count function on my computer.
/s/ Linda Icenhauer-Ramirez
LINDA ICENHAUER-RAMIREZ
CERTIFICATE OF SERVICE
I, Linda Icenhauer-Ramirez, hereby certify that a true and correct copy of the
foregoing Appellant’s First Motion for Extension of Time to Brief was served by e-file to
the Travis County District Attorney's Office on this the 9th day of November, 2015.
/s/ Linda Icenhauer-Ramirez
LINDA ICENHAUER-RAMIREZ
Christopher German Reyes v. State
Combined Opinion