39 N.E.3d 380
Tex. App.
2015

JOHN LEE BOWMAN, Appellant v. THE STATE OF TEXAS, Appellee

No. 03-15-00263-CR

In the COURT OF APPEALS For the THIRD SUPREME JUDICIAL DISTRICT at Austin

10/5/2015

On Appeal from the 264th Judicial District Court of Bell County, Texas Cause Number 73061

APPELLANT‘S MOTION FOR EXTENSION OF TIME

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF APPEALS:

COMES NOW, John Lee Bowman, 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 was due in this case on October 2, 2015.
  2. Appellant seeks an extension of sixty days in which to file his brief, making his brief due on or before December 1, 2015.
  3. In the past thirty days, the undersigned was counsel of record in the two-week murder trial of The State of Texas v. Daniel Willis, No. 15,605 in the 21st District Court of Bastrop County. Additionally, in the past thirty days, the undersigned has filed a brief in the First Court of Appeals in Cause Number 01-14-01023-CR, Sean Michael McGuire v. The State of Texas. The undersigned also filed a brief in the Third Court of Appeals in Cause Number 03-15-00024-CR, Steven Anthony Roe v. The State of Texas. Further, on September 9, 2015, the undersigned was the attorney of record in a contested hearing in the 434th District Court of Fort Bend County in the Capital Murder case of Cornelius Harper v. The State of Texas, No. 01-14-00641-CR. Finally, the undersigned has undertaken the tasks associated with a solo practice. Consequently, the undersigned respectfully requests that the Court grant Appellant the additional time.
  4. The undersigned has not filed any previous motions 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 December 1, 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 Bell County District Attorney‘s Office, 1200 Huey Road, Belton, Texas 76513 on October 5, 2015.

/s/ Kristen Jernigan

Kristen Jernigan