ACCEPTED
03-16-00483-CR
12960151
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/28/2016 4:41:53 PM
JEFFREY D. KYLE
CLERK
NO. 03-16-00483-CR
IN THE COURT OF APPEALS FILED IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
FOR THE 9/28/2016 4:41:53 PM
JEFFREY D. KYLE
THIRD SUPREME JUDICIAL DISTRICT Clerk
AT AUSTIN, TEXAS
JAMIE PETRONELLA,
Appellant
vs.
THE STATE OF TEXAS,
Appellee
Appeal from the 33rd Judicial District Court
Cause No. CR01362
Blanco County, Texas
The Honorable J. Allan Garrett, Judge Presiding
APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME
Gary E. Prust
State Bar No. 24056166
1607 Nueces Street
Austin, Texas 78701
(512) 469-0092
Fax: (512) 469-9102
gary@prustlaw.com
ATTORNEY FOR APPELLANT
ORAL ARGUMENT IS NOT REQUESTED
APPELLANT’S REQUEST FOR EXTENSION OF TIME TO FILE BRIEF
Appellant, Jamie Petronella, by and through her counsel, files this request
for extension of time, and in support thereof shows as follows.
I.
1. Appellant's Motion is brought pursuant to TEX.R.APP.P 10.5(b).
2. Appellant has not previously requested an extension of time in which to file
her brief.
3. Appellant's brief was due on September 21, 2016.
4. Appellant's attorney was also scheduled for numerous jury trial settings and
numerous appellate deadlines in August and into the month of September.
5. Appellant’s court appointed counsel has a vacation scheduled where he will
be out of the country from October 9, 2016 through October 22, 2016.
6. In order to address the issues raised in the present appeal thoroughly,
Appellant's attorney will require more time to complete his brief. Appellant’s
attorney will require until November 21, 2016 to complete his brief.
7. Accordingly, Appellants request that this Court allow him until November
21, 2016 to file his brief.
2
Respectfully submitted,
Gary E. Prust
SBN 24056166
1607 Nueces Street
Austin, Texas 78701
(512) 469-0092
Fax: (512) 469-9102
gary@prustlaw.com
Attorney for Appellant
CERTIFICATE OF SERVICE
In compliance with Rule 9.5(d) of the Texas Rules of Appellate Procedure,
the undersigned attorney certifies that a true and correct copy of the foregoing
Motion was served upon the Blanco County Attorney via electronic transmission,
in accordance Rule 9.5(b) of the Texas Rules of Appellate Procedure on this the
28th day of September, 2016.
Gary E. Prust
3
CERTIFICATE OF COMPLIANCE
Pursuant to TEX. R. APP. PROC. 9.4(i)(3), I hereby certify this motion
contains 157 words. This is a computer-generated document created in Microsoft
Word, using 14-point typeface. In making this this certificate, I rely on the word
count provided by the software use to prepare the document.
Gary E. Prust
4