Karra Trichele Allen v. State

Opinion

ACCEPTED 03-15-00420-CR 7381776 THIRD COURT OF APPEALS AUSTIN, TEXAS 10/14/2015 6:23:27 PM JEFFREY D. KYLE CLERK NO. 03-15-00420-CR

FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS IN THE COURT OF APPEALS 10/14/2015 6:23:27 PM FOR THE JEFFREY D. KYLE THIRD SUPREME JUDICIAL DISTRICT Clerk AT AUSTIN, TEXAS

KARRA TRICHELE ALLEN, Appellant

vs.

THE STATE OF TEXAS, Appellee

Appeal from the 33rd Judicial District Court Cause No. 42765 Burnet 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 FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF

Appellant, Karra Trichelle Allen, file this, her “First Motion for Extension of

Time to File Brief,” 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 requested previously an extension of time within which to

file her brief.

3. Appellant's brief is due on October 15, 2015.

4. Appellant's attorney had a very busy trial schedule during the months of

September and October 2015. In addition, the reporter’s record in this cause is

substantial, consisting of 18 volumes of transcribed hearings and an additional 3

volumes of exhibits.

5. 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 December 15, 2015 to complete his brief.

6. Accordingly, Appellant requests that this Court allow her until December

15, 2015 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

3 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 Mr. Gary Bunyard, assistant district attorney, via electronic transmission through efile.txcourts.gov accordance Rule 9.5(b) of the Texas Rules of Appellate Procedure on this the 14th day of October, 2015.

Gary E. Prust

CERTIFICATE OF COMPLIANCE

Pursuant to TEX. R. APP. PROC. 9.4(i)(3), I hereby certify this brief contains 151 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.

CERTIFICATE OF CONFERENCE

This is to confirm I conferred with Mr. Gary Bunyard regarding this motion and he expressed no opposition.