David Patrick Bertram v. State

• Court: Court of Appeals of Texas
• Decided: March 20, 2018
• Docket: 01-17-00940-CR
• Status: Published

Opinion

ACCEPTED 01-17-00940-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 3/20/2018 3:26 PM CHRISTOPHER PRINE CLERK

NOS. 01-17-00940-CR

IN THE COURT OF APPEALS FILED IN FOR THE FIRST DISTRICT OF TEXAS 1st COURT OF APPEALS HOUSTON, TEXAS 3/20/2018 3:26:02 PM CHRISTOPHER A. PRINE DAVID BERTRAM Clerk Appellant

v.

THE STATE OF TEXAS Appellee

On Appeal from Cause Number 1519159 From the 178th District Court of Harris County, Texas

APPELLANT’S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE AN APPELLATE BRIEF

To the Honorable Court of Appeals of Texas:

Comes now Appellant, in accordance with Rules 10.5(b)(1) and 38.6(d) if the

Texas Rules of Appellate Procedure, and files this motion for extension of time in

which to file the Appellant’s brief in this cause and, in support thereof, presents the

following:

1. In the 178th District Court of Harris County, Texas, following a jury trial,

Appellant was found guilty on November 29, 2017, in Cause Number 1519159,

The State of Texas v. David Bertram for Attempted Aggravated Kidnapping and sentenced to 50 years in the Institutional Division of the Texas

Department of Criminal Justice on each count.

2. A written notice of appeal was timely filed on November 29, 2017.

3. The Appellant’s brief is due on March 19, 2018.

4. Appellant requests an extension of time in which to file his brief until April 20,

2018.

5. No prior extensions have been requested or granted.

6. The facts relied upon to explain the need for this extension are:

a. Appellant’s counsel requires additional time to adequately research the

issues in this case and write a brief on his behalf.

Consequently, additional time will be necessary in which to file Appellant’s

brief in this case. The Appellant’s motion is not for purposes of delay, but so that

justice may be done.

WHEREFORE, the Appellant Prays that this Court will grant an additional

extension of time until April 20, 2018, in which to file Appellant’s brief in this case.

Respectfully submitted,

_s/Tonya Rolland Tonya Rolland 1225 N Loop W, Suite 640 Houston, Texas 77008 Phone: (713) 529-8500 Fax: (713) 453-2203 TBN 24054176 tonya@rollandlaw.com

CERTIFICATE OF SERVICE

This is to certify that a copy of the foregoing instrument has been delivered via e-service to the following:

mccrory_daniel@dao.hctx.net Assistant District Attorney Harris County District Attorney’s Office Houston, Texas 77002

_s/Tonya Rolland Tonya Rolland