Joe Derek Carr v. State

Opinion

ACCEPTED

03-14-00234-CR

4065029

THIRD COURT OF APPEALS

AUSTIN, TEXAS

2/8/2015 8:15:50 PM

JEFFREY D. KYLE

CLERK

No. 03-14-00234-CR

In the February 9, 2015 COURT OF APPEALS

For the

THIRD SUPREME JUDICIAL DISTRICT at Austin

______________________________________

On Appeal from the 167th Judicial District Court of Travis County, Texas

Cause Number D-1-DC-11-100059

______________________________________

JOE DEREK CARR, Appellant v.

THE STATE OF TEXAS, Appellee

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APPELLANT’S MOTION FOR EXTENSION OF TIME

______________________________

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF

APPEALS:

COMES NOW, Joe Derek Carr, Appellant herein, by and through his

attorney of record, Kristen Jernigan, and files this, his Motion for Extension of

Time. In support of said motion, Appellant would show the Court the following:

1. Appellant’s brief was due in this case on January 19, 2015.

2. Appellant seeks an extension of sixty days in which to file his brief, making his brief due on or before March 19, 2015.

3. The undersigned inadvertently calendared the due date for Appellant’s brief as February 19, 2015.

4. In the past thirty days, the undersigned has filed briefs in the First

Court of Appeals in Cause Numbers 01-14-00240-CR, Sean Michael McGuire, v. The State of Texas; and 01-14-00241-CR, Sean Michael McGuire v. The State of Texas. In addition, the undersigned filed a Petition for Writ of Habeas Corpus in Cause Number 08-1623-K26, Ex parte Adam Adel Hayek. Finally, the undersigned has made numerous court appearances and has undertaken the tasks associated with the management of a solo attorney practice.

5. The undersigned has filed one previous motion for extension of time in this case.

6. For the reasons set forth above, Appellant respectfully requests that he be granted an extension of sixty days so that his brief in this case will now be due on March 19, 2015.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully

requests that this Court grant his Motion for Extension of Time.

Respectfully submitted,

_______/s/__Kristen Jernigan______ KRISTEN JERNIGAN State Bar Number 90001898 207 S. Austin Ave. Georgetown, Texas 78626 (512) 904-0123 (512) 452-1382 (fax) Kristen@txcrimapp.com

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the

foregoing Appellant’s Motion for Extension of Time has been mailed to the Travis

County District Attorney’s Office, P.O. Box 1748, Austin, Texas, 78767, on

February 9, 2014.

__/s/ Kristen Jernigan__________________ Kristen Jernigan