Troy Luther Williams v. State

Opinion

ACCEPTED

03-14-00228-CR

3683866

THIRD COURT OF APPEALS

AUSTIN, TEXAS

1/7/2015 2:45:34 PM

JEFFREY D. KYLE

CLERK

IN THE THIRD COURT OF APPEALS FOR THE STATE OF TEXAS

FILED IN

3rd COURT OF APPEALS

TROY WILLIAMS AUSTIN, TEXAS 1/7/2015 2:45:34 PM

V. NO. 3-14-00228-CR JEFFREY D. KYLE

Clerk

THE STATE OF TEXAS

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

TO THE HONORABLE THIRD COURT OF APPEALS:

COMES NOW, Troy Williams, by and through his attorney of record, Linda Icenhauer-Ramirez, and files this his First 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. Troy Williams, Cause Number D-1-DC-12-904077 in the 147th Judicial District Court of Travis County, Texas. Appellant was sentenced on April 4, 2014.

II.

Appellant was convicted of the offense of aggravated kidnapping and punishment was assessed at sixty (60) years.

III.

Appellant’s motion for new trial was filed on April 10, 2014. Notice of appeal was filed on April 10, 2014. The reporter’s record was filed on December 2, 2014, and the clerk’s record was filed on August 4, 2014. The due date for the brief is Wednesday, January 7, 2015.

IV.

This is Appellant’s first motion for extension of time to file his brief. Appellant respectfully requests a forty-five day extension of time to file the brief, which would make such brief due on Saturday, February 21, 2015. The next working day is Monday, February 23, 2015.

V.

The undersigned attorney has begun work on this case but has been unable to complete the brief due to necessary work needed to be completed on several other appeal cases and due to her busy schedule in both the district and county courts of Travis, Williamson and Hays Counties. She has recently filed a brief in the case of Jesus Villalobos v. State of Texas, Cause No. 03-13-00687-CR. She is in the process of completing a brief in the case of Edward Garcia v. State of Texas, Cause No. 03-14- 00269-CR which is due next week. 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 452 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 First Motion for Extension of Time to Brief was served by e-file to the Travis County District Attorney's Office on this the 7th day of January, 2015.

/s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ