Miguel MacIas v. State

Opinion

ACCEPTED

14-15-00030-CR

FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 4/17/2015 4:02:27 PM CHRISTOPHER PRINE

CLERK

No. 14-15-00030-CR

In the FILED IN 14th COURT OF APPEALS

COURT OF APPEALS HOUSTON, TEXAS For the 4/17/2015 4:02:27 PM FOURTEENTH SUPREME JUDICIAL DISTRICT CHRISTOPHER A. PRINE at Houston Clerk

______________________________________

On Appeal from the 427th District Court of Travis County, Texas

Cause Number D-1-DC-13-30173

______________________________________

MIGUEL MACIAS, Appellant

v.

THE STATE OF TEXAS, Appellee

_____________________________________

APPELLANT’S MOTION FOR EXTENSION OF TIME

______________________________

TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF

APPEALS:

COMES NOW, Miguel Macias, Appellant herein, by and through his

attorney of record, Kristen Jernigan, and files this, his Motion for Extension of

Time. In support of said motion, Appellant would show the Court the following:

1. Appellant’s brief is due in this case on April 17, 2015.

2. Appellant seeks an extension of sixty day in which to file his brief, making his brief due on or before June 16, 2015.

3. On March 16, 2015, the undersigned sent a written request for the clerk’s record and reporter’s record on disk, along with a check for $1.00 and a stamped, self-addressed envelope, as directed by the Clerk’s Office. The request informed this Court that the undersigned is Court-appointed. To date, the undersigned has not received the clerk’s record or the reporter’s record from this Court.

4. In the past thirty days, the undersigned has filed a brief in the Fourteenth Court of Appeals in Cause Number 14-15-00053-CR, Joseph Henry Edward Haynes v. The State of Texas. The undersigned filed a brief in the Third Court of Appeals in Cause Number 03-14-00599-CR, Timothy Colt Castleberry v. The State of Texas. Additionally, the undersigned filed a letter brief in the Tenth Court of Appeals in Cause Number 10-14-00227-CR, Pedro Rodriguez, Jr. v. The State of Texas. Further, the undersigned filed a Response to the State’s Petition for Petition for Discretionary Review in Cause Number PD-0280-15, The State of Texas v. John Allen Wachtendorf. Moreover, the undersigned filed a Supplemental Memorandum in Support of Habeas Corpus Relief in WR-82,426-02, Ex parte Robert Jesse Padilla, Jr. Finally, the undersigned has made numerous court appearances and has undertaken the tasks associated with the management of a solo attorney practice.

5. The undersigned has not filed any previous motions for extension of time in this case.

6. For the reasons set forth above, Appellant respectfully requests that he be granted an extension of sixty days so that his brief in this case will now be due on June 16, 2015.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully

requests that this Court grant his Motion for Extension of Time.

Respectfully submitted,

_______/s/__Kristen Jernigan______ KRISTEN JERNIGAN State Bar Number 90001898 207 S. Austin Ave. Georgetown, Texas 78626 (512) 904-0123 (512) 931-3650 (fax) Kristen@txcrimapp.com

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the

foregoing Appellant’s Motion for Extension of Time has been mailed to the Travis

County District Attorney’s Office, P.O. Box 1748, Austin, Texas 78767 on April

17, 2015.

__/s/ Kristen Jernigan__________________ Kristen Jernigan