Linda Woodman v. State

Opinion

ACCEPTED

14-15-00033-CR

FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS

8/3/2015 8:52:05 AM

CHRISTOPHER PRINE

CLERK

IN THE FOURTEENTH COURT OF APPEALS FOR THE STATE OF TEXAS

FILED IN

14th COURT OF APPEALS

HOUSTON, TEXAS

LINDA WOODMAN 8/3/2015 8:52:05 AM CHRISTOPHER A. PRINE

V. NO. Clerk 14-15-00033-CR

THE STATE OF TEXAS

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

TO THE HONORABLE FOURTEENTH COURT OF APPEALS:

COMES NOW, Linda Woodman, by and through her attorney of record, Linda Icenhauer-Ramirez, and files this her 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. Linda Woodman, Cause Number D-1-DC-14-904029 in the 147th Judicial District Court of Travis County, Texas. Appellant was sentenced on September 2, 2014.

II.

Appellant was convicted of the offense of aggravated assault and punishment was assessed at thirteen years (13) years and a $10,000.00 fine.

III.

Appellant’s motion for new trial was filed on September 23, 2014.

Notice of appeal was filed on November 25, 2014. The reporter’s record was filed on May 18, 2015, and the clerk’s record was filed on December 22, 2014. The due date for the brief is Monday, August 3, 2015.

IV.

This is Appellant’s second motion for extension of time to file her brief. Appellant respectfully requests a forty-five day extension of time to file the brief, which would make such brief due on Thursday, September 17, 2015.

V.

The undersigned attorney has read the lengthy appellate record in this case. She has begun researching the applicable law and has begun drafting the brief. However she has been unable to complete the brief due to necessary work that needed to be completed on several other appeal cases and due to her busy schedule in both the district and county courts of Travis County and Williamson County. She recently completed and filed a brief in the case of Levardo Cantos v. State of Texas, Cause No. 03-14-00585-CR which was due on July 10, 2015. She also completed and filed a brief in the case of James Palacio v. State of Texas, Cause No. 03-14-00654-CR which was due on July 20, 2015. In addition she had to file a motion for rehearing in the case of John Frederick Zedler v. State of Texas, Cause No. 03-14- 00044-CR on July 27, 2015. She will now devote her full attention to completing the brief in this case and will have it completed by September 17, 2015. 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

CERTIFICATE OF COMPLIANCE I hereby certify that this motion was computer generated and contains 525 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 the Travis County District Attorney's Office on this the 3rd day of August, 2015.

/s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ