Karl Dean Stahmann v. State

Opinion

ACCEPTED 03-15-00068-CR 4902952 THIRD COURT OF APPEALS AUSTIN, TEXAS 4/15/2015 3:16:41 PM JEFFREY D. KYLE CLERK Cause No. - -- --

IN THE THRID COURT OF APPEALS FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS KARL STAHMANN 4/15/2015 3:16:41 PM Appellant § JEFFREY D. KYLE § Clerk v. § 03 -15-00068-CR § § THE STATE OF TEXAS §

APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUDGES OF THE THIRD COURT OF APPEALS:

COMES NOW APPELLANT, KARL STAHMANN, by and through his

undersigned counsel, and pursuant to Rule 10.5(b) of the Texas Rules of Appellate

Procedure, requests an extension of time to file appellant's brief. In support of this

motion, Appellant submits the following:

I.

The deadline for filing Appellant's Brief is March 30, 2015. T.R.A.P. 4.1(a).

II.

Appellant requests an extension of sixty (60) days in which to file his Appellant's

Brief. T.R.A.P. 68.2(c).

Page 1 of3 III.

Undersigned counsel was actively preparing for a jury trial, namely: The State of

Texas v. Xavier Harper (CR-14-0270). Counsel was in a jury trial on March 8-13, 2015

in The State of Texas v. Audrina Torres (C-1-CR-14-211696). Undersigned counsel was

also actively in a Motion to Suppress Hearing on three separate occasions for The State of

Texas v. Christi Lane (D-1-DC-13-205887, D-1-DC-13-302070 and D-1-DC-14-300739).

PRAYER

Wherefore, premises considered, undersigned counsel prays for this Court to

extend the time for filing Appellant's brief as sixty days from April 15, 2015, which

would make the brief due on Friday, June 12, 2015.

Respectfully submitted,

CHARLES F. BAIRD SBN #00000065 BAIRD FARRELLY, PLLC 2312 Western Trails Blvd, Suite 102-A Austin, Texas 78745 Tel: 512-804-5911 Fax: 512-804-5919 Email: jcfbaird@gmail.com ATTORNEY FOR APPELLANT

Page 2 of3 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of this Motion was provided to the Comal County District Attorney and the State Prosecuting Attorney on April 15, 2015, via fax at (830) 608-2008.

CHARLES F. BAIRD

Page 3 of3