Case Information
*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 8/3/2015 8:52:05 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-15-00033-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 8/3/2015 8:52:05 AM CHRISTOPHER PRINE CLERK IN THE FOURTEENTH COURT OF APPEALS
FOR THE STATE OF TEXAS LINDA WOODMAN
V. NO. 14-15-00033-CR
THE STATE OF TEXAS
APPELLANT’S SECOND MOTION FOR
EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE FOURTEENTH COURT OF APPEALS:
COMES NOW, Linda Woodman, by and through her attorney of
record, Linda Icenhauer-Ramirez, and files this her Second 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. Linda Woodman, Cause Number D-1-DC-14-904029 in the 147th
Judicial District Court of Travis County, Texas. Appellant was sentenced on
September 2, 2014.
II.
Appellant was convicted of the offense of aggravated assault and
punishment was assessed at thirteen years (13) years and a $10,000.00 fine.
III.
Appellant’s motion for new trial was filed on September 23, 2014.
Notice of appeal was filed on November 25, 2014. The reporter’s record
was filed on May 18, 2015, and the clerk’s record was filed on December
22, 2014. The due date for the brief is Monday, August 3, 2015.
IV.
This is Appellant’s second motion for extension of time to file her
brief. Appellant respectfully requests a forty-five day extension of time to
file the brief, which would make such brief due on Thursday, September 17,
2015.
V.
The undersigned attorney has read the lengthy appellate record in this
case. She has begun researching the applicable law and has begun drafting
the brief. However she has been unable to complete the brief due to
necessary work that needed to be completed on several other appeal cases
and due to her busy schedule in both the district and county courts of Travis
County and Williamson County. She recently completed and filed a brief in
the case of Levardo Cantos v. State of Texas, Cause No. 03-14-00585-CR
which was due on July 10, 2015. She also completed and filed a brief in the
case of James Palacio v. State of Texas, Cause No. 03-14-00654-CR which
was due on July 20, 2015. In addition she had to file a motion for rehearing
in the case of John Frederick Zedler v. State of Texas, Cause No. 03-14-
00044-CR on July 27, 2015. She will now devote her full attention to
completing the brief in this case and will have it completed by September
17, 2015. 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
525 words, as calculated by the word count function on my computer.
/s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ *4 CERTIFICATE OF SERVICE I, Linda Icenhauer-Ramirez, hereby certify that a true and correct
copy of the foregoing Appellant’s Second Motion for Extension of Time to
Brief was served by e-file to the Travis County District Attorney's Office on
this the 3rd day of August, 2015.
/s/ Linda Icenhauer-Ramirez LINDA ICENHAUER-RAMIREZ