Leovardo Cantos v. State

Opinion

ACCEPTED 03-14-00585-CR 4813868 THIRD COURT OF APPEALS AUSTIN, TEXAS 4/8/2015 3:59:02 PM JEFFREY D. KYLE CLERK IN THE THIRD COURT OF APPEALS FOR THE STATE OF TEXAS FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS LEVARDO CANTOS 4/8/2015 3:59:02 PM JEFFREY D. KYLE V. NO. Clerk 3-14-00585-CR

THE STATE OF TEXAS

APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE THIRD COURT OF APPEALS:

COMES NOW, Leovardo Cantos, by and through his attorney of

record, Linda Icenhauer-Ramirez, and files this his Second Motion for

Extension of Time to Brief and in support thereof, would show the Court the

following:

I.

That the above-styled and numbered cause is styled The State of

Texas v. Levardo Cantos, Cause Number 13-2081-K277 in the 277th

Judicial District Court of Travis County, Texas. Appellant was sentenced on

August 11, 2014.

II.

Appellant was convicted of the offense of aggravated assault with

serious bodily injury and punishment was assessed at fifteen (15) years. III.

Appellant’s motion for new trial was filed on September 10, 2014.

Notice of appeal was filed on September 10, 2014. The reporter’s record

was filed on January 15, 2015, and the clerk’s record was filed on January

15, 2015. The exhibits were filed on January 23, 2015. The due date for the

brief is Thursday, April 9, 2015.

IV.

This is Appellant’s second motion for extension of time to file his

brief. Appellant respectfully requests a forty-five day extension of time to

file the brief, which would make such brief due on Sunday, May 24, 2015.

The next working day is Monday, May 25, 2015.

V.

The undersigned attorney has begun work on this case but has been

unable to complete the brief due to necessary work needed to be completed

on several other appeal cases and due to her busy schedule in both the

district and county courts of Travis, Williamson and Hays Counties. She

recently filed a supplemental brief in the case of In the Matter of J.M., 03-

14-00027-CV and she is preparing for oral argument in that case on April

22, 2015. This next week she will be filing a brief in the case of State of

Texas v. Brian Roland Chandler, Cause No. 03-14-00547-CR, and she is also working on briefs in the cases of Troy Luther Williams v. State of

Texas, Cause Nos. 03-14-00228-CR and 03-14-00229-CR. She asks that

this extension be granted so that she may effectively represent Appellant and

so that justice may be done in this case.

Respectfully Submitted

/s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ Attorney at Law 1103 Nueces Austin, Texas 78701 (512) 477-7991 FAX #: (512) 477-3580 SBN: 10382944 EMAIL: ljir@aol.com

ATTORNEY FOR APPELLANT ON APPEAL ONLY

CERTIFICATE OF COMPLIANCE

I hereby certify that this motion was computer generated and contains

498 words, as calculated by the word count function on my computer.

/s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ CERTIFICATE OF SERVICE

I, Linda Icenhauer-Ramirez, hereby certify that a true and correct

copy of the foregoing Appellant’s Second Motion for Extension of Time to

Brief was served by e-file to John Prezas of the Williamson County District

Attorney's Office on this the 8th day of April, 2015.

/s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ