Case Information

*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 2/27/2015 3:53:35 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-15-00036-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 2/27/2015 3:53:35 PM CHRISTOPHER PRINE CLERK

IN THE TEXAS COURT OF APPEALS

FOURTEENTH APPELLATE DISTRICT

HOUSTON, TEXAS §

JUSTIN PARKER RUSSELL

§ Cause No. 14-15-00036-CR §

v.

§ §

STATE OF TEXAS

MOTION FOR EXTENSION OF TIME TO FILE APPELLATE BRIEF

TO THE HONORABLE JUSTICES OF THIS COURT:

COMES NOW JUSTIN RUSSELL, Appellant in the above-entitled and numbered

cause, by and through undersigned counsel, and respectfully moves this honorable Court

to extend the briefing deadline set in this cause. In support of the same, undersigned

would show this Court as follows: Justin Russell was convicted in cause number CR2013-379 in the 433 rd

1.

Judicial District of Comal County Texas for the felony offense of Driving While

Intoxicated. Mr. Russell perfected his appeal to the Third Court of Appeals in Austin, and

the cause was transferred to this Honorable Court pursuant to a Supreme Court Transfer

Order issued December 15, 2014. Undersigned received the completed Reporter’s Record

in this cause on February 6, 2015. This Court has set March 9, 2015, as the briefing

deadline for the Appellant

2. Undersigned has worked diligently to review the Clerk’s and Reporter’s

Records in this cause and prepare Appellants legal arguments, but requires additional time

to research the legal issues raised by the record and prepare Appellant’s brief. Undersigned

is also preparing for a jury trial in County Court at Law Number Eleven of Bexar County,

Texas on Monday, March 2, 2015. Undersigned is also in the process of changing his place

of residence, and is scheduled to close on his new residence on the morning of March 2 nd

before his jury trial commences. Although undersigned will continue to work diligently as

time permits next week, these professional and personal obligations make completion of the

brief by March 9 very difficult to accomplish.

3. This request for an extension of time is sought not for the purposes of delay,

but that justice may be done.

4. This is Appellant’s first motion for an extension of time.

WHEREFORE, PREMISES CONSIDERED, Appellant prays this honorable Court

to grant a 45-day extension of time to complete and file his appellate brief in this cause.

Respectfully Submitted,

State Bar No. 24077532

T HE L AW O FFICE OF J OHN H UNTER

310 S. St. Mary’s Street

Suite 1840 – Tower Life Bldg.

San Antonio, Texas 78205

(210) 399-8669

(210) 568-4927 telecopier

JTH753@gmail.com

Attorney for Justin P. Russell

CERTIFICATE OF SERVICE

This certifies that on the 27 day of February 2015, a true and correct copy of the

above and foregoing document was served on the Comal County District Attorney’s Office

via facsimile to (830) 608-2008.