Steven Anthony Roe v. State

Opinion

ACCEPTED 03-15-00024-CR 6391092 THIRD COURT OF APPEALS AUSTIN, TEXAS 8/6/2015 3:37:10 PM JEFFREY D. KYLE CLERK No. 03-15-00024-CR

In the FILED IN 3rd COURT OF APPEALS COURT OF APPEALS AUSTIN, TEXAS For the 8/6/2015 3:37:10 PM THIRD SUPREME JUDICIAL DISTRICT JEFFREY D. KYLE at Austin Clerk ______________________________________

On Appeal from the 368th Judicial District Court of Williamson County, Texas Cause Number 13-0686-K277 ______________________________________

STEVEN ROE, Appellant v. THE STATE OF TEXAS, Appellee _____________________________________

APPELLANT’S MOTION FOR EXTENSION OF TIME ______________________________

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF

APPEALS:

COMES NOW, Steven Roe, 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 August 7, 2015.

2. Appellant seeks an extension of sixty days in which to file his brief, making his brief due on or before October 6, 2015.

3. In the past sixty days, the undersigned has filed a brief in the Fourteenth Court of Appeals in Cause Number 14-15-00030-CR, Miguel Macias v. The State of Texas. The undersigned also filed briefs in the Thirteenth Court of Appeals in Cause Numbers 13-13-00547-CR, 13-13-00548-CR, and 13-13-00549-CR, John Steen v. The State of Texas. In addition, the undersigned is currently drafting a brief in the Cause Number 01-14-00641-CR, Cornelius Milan Harper v. The State of Texas, which is a capital murder case in which the record consists of seventy-one volumes. Further, the undersigned filed a Motion for Bond Pending Final Determination of Appeal in the Thirteenth Court of Appeals in Cause Number 13-13-00172-CR, Abraham Jacob Proenza v. The State of Texas in a case in which the Thirteenth Court of Appeals reversed Mr. Proenza’s conviction. Finally, the undersigned has made numerous court appearances and has undertaken the tasks associated with the management of a solo attorney practice.

4. The undersigned has filed one previous motion for extension of time in this case.

5. 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 October 6, 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) 452-1382 (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 emailed to John C.

Prezas, Appellate Attorney for the Williamson County District Attorney’s Office,

at jprezas@wilco.org on August 6, 2015.

__/s/ Kristen Jernigan__________________ Kristen Jernigan