Michelle Elaine Gambles v. State

Opinion

ACCEPTED

03-14-00484-CR

4550087

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/18/2015 3:06:30 PM

JEFFREY D. KYLE

CLERK

NO. 03-14-00484-CR

FILED IN

STATE OF TEXAS § IN THE 3rd COURT OF APPEALS AUSTIN, TEXAS

§

3/18/2015 3:06:30 PM

VS. § THIRD COURT JEFFREY D. KYLE

§ Clerk MICHELLE ELAINE GAMBLES § OF APPEALS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes MICHELLE ELAINE GAMBLES, Appellant in the above styled and numbered cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the County Court at Law Number 2 of Bell County, Texas. 2. The case below was styled the STATE OF TEXAS vs. MICHELLE ELAINE GAMBLES, and numbered 2C13-07485. 3. Appellant was convicted of Resisting Arrest. 4. Appellant was assessed a sentence of 6 days on July 16, 2014. 5. Notice of appeal was given on August 4, 2014. 6. The clerk's record was filed on September 5, 2014; the reporter's record was filed on January 9, 2015. 7. The appellate brief is presently due on March 9, 2015.

8. Appellant requests an extension of time of 60 days from the present date, i.e. May 8, 2015. 9. One extension to file the brief has been received in this cause. 10. Defendant is currently free on bond. 11. Appellant relies on the following facts as good cause for the requested extension: Counsel for Appellant has been preparing briefs in other cases, in addition to normal practice placing constraints on available time .. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this Motion To Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate.

Respectfully submitted,

BOBBY DALE BARINA

455 East Central Texas Expressway, Suite 104

Harker Heights, Texas 76548 Tel: (254) 699-3755

Fax: (254) 699-1074

BobbyDaleBarina@BarinaLaw.com

f)!Jrl ;LtW~Lf Jc;.O

bobbydalebarina@barinalaw.com Attorney for MICHELLE ELAINE GAMBLES

CERTIFICATE OF SERVICE

This is to certify that on March 18, 2015, a true and correct copy of the above and foregoing document was served on the County Attorney's Office, Bell County, Bell county Justice Complex, by fax to (254) 933-5150.

-for o/v~ALE BARINA

STATE OF TEXAS § §

COUNTY OF BELL §

AFFIDAVIT

BEFORE ME, the undersigned authority, on this day personally appeared BOBBY DALE BARINA, who after being duly sworn stated: "I am the attorney for the appellant in the above numbered and entitled cause. I have read the foregoing Motion To Extend Time to File Appellant's Brief and swear that all of the allegations of fact contained therein are true and correct."

T RWOUDWYK

ffiant

SUBSCRIBED AND SWORN TO BEfORE ME on ' 2015, I I

to certifY which witness my hand and eal o fit.

I

~~\t¥J~¥;;--~ LESLIE JOAN SAWYER ~~~"'\ Notary Public, State of Texas ;,;:.~i.. S My Commission Expires ~~ ..~~ April 06, 201S