Ariana Oliveira v. State

Opinion

ACCEPTED

03-14-00816-CR

4796156

THIRD COURT OF APPEALS

AUSTIN, TEXAS

4/7/2015 4:24:04 PM

JEFFREY D. KYLE

CLERK

NO. 03-14-00816-CR

ARIANA OLIVEIRA § FILED IN IN THE THIRD COURT

3rd COURT OF APPEALS

AUSTIN, TEXAS

v. § OF APPEALS 4/7/2015 4:24:04 PM

JEFFREY D. KYLE

Clerk

THE STATE OF TEXAS § AUSTIN, TEXAS

SECOND MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

COMES NOW Ariana Oliveira, Appellant in the above-styled and numbered

cause, by and through her undersigned counsel, and respectfully moves this Court to

extend the time to file Appellant's brief. In support thereof, and pursuant toTEX. R.

APP. PROC. 10.5(b), Appellant would show as follows:

(A) Appellant's Brief is due onApril10, 2015;

(B )Appellant seeks a second 3 0 day extension;

(C)Undersigned counsel previously requested his first extension due to

preparation for a sentencing on March 6, 2015 (State of Texas vs. Juan Jose

Santos, Cause Number D-1-DC-13-900244 in the 403rd District Court of

Travis County, Texas). However, onMarch6, 2015, Mr. Santos rejected the

states Plea offer and his case of continuous sexual assault of a child is set to

be tried April20, 2015. Undersigned counsel anticipates that he will have

adequate time to research the law, and complete his brief if this Court grants

a second 3 0-day extension;

(D) Only one previous extension has been requested and granted.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that the foregoing

motion be GRANTED.

Respectfully submitted,

Is/ Joshua D. Saegert JOSHUA D. SAEGERT Law Office of Joshua D. Saegert 609 W. 9th Street Austin, Texas 78701 Phone: (512) 371-3477 Fax: (512) 236-9287 saegertlaw@yahoo.com State Bar No. 90001888 ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Second Motion to

Extend Time to File Appellant's Brief was emailed to the Travis County Attorney's

Office, Appellate Division, 314 W. 11th St., Suite 400, Austin, Texas, 78701, on this

the ih day of April, 20 15.

Is! Joshua D. Saegert JOSHUA D. SAEGERT