Robert Paradise v. State

Opinion

ACCEPTED 03-15-00560-CR 8392900 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/29/2015 1:38:42 PM JEFFREY D. KYLE CLERK No. 03-15-00560-CR

ROBERT PARADISE, ) COURT OF APPEALS, THIRD FILED IN Appellant ) 3rd COURT OF APPEALS ) AUSTIN, TEXAS vs. ) SUPREME mDICIAL 12/29/2015 DISTRICT1:38:42 PM ) JEFFREY D. KYLE STATE OF TEXAS, ) Clerk Appellee ) AUSTIN, TEXAS

APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE mDGE OF SAID COURT:

COMES NOW, Appellant, by and throughhis attorney ofrecord, and respectfully files

this his First Motion for Extension of Time to File Brief and requests this extension of time to

file his appellate brief in this cause herein, and for cause would show the Court the following:

I.

The Appellant, ROBERT PARADISE, was convicted in Cause No. B-12-0414-SB, in the

119m District Court of Tom Green County, Texas, of the offense of arson as a result of a trial

before the Court. Defendant's punishment was assessed at forty (40) years confinement in the

Texas Department of Criminal Justice - Institutional Division.

II.

The Statement of Facts has been filed with the Court.

III.

The deadline for filing the Appellant's brief is January 11,2016. The undersigned attorney

would show the Court that he has insufficient time within which to file the brief by the deadline of

January 11,2016 because ofhis current caseload and trial schedule for the month of January 2016. IV. The undersigned counsel would respectfully request that the Court grant an extension of

forty-five (45) days' time to file the appellate brief.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays the Court

grant this motion for extension of time to file the appellate brief.

~ ~--------------~ P.O. BOX 3645 SAN ANGELO, TEXAS 76902 325/658-5585 STATE BAR NO. 09250400

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has this the 3..:1_ day of December, 2015, been delivered to Mr. Bryan Clayton, Assistant District Attorney, 124 West Beauregard, San Angelo, Texas 76903. ~

Kirk Hawkins