Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/7/2015 3:24:16 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-14-01023-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 7/7/2015 3:24:16 PM CHRISTOPHER PRINE CLERK No. 01-14-01023-CR In the COURT OF APPEALS For the FIRST JUDICIAL DISTRICT at Houston On Appeal from the 240th Judicial District Court of Fort Bend County, Texas in Cause Number 10-DCR-055898 THE STATE OF TEXAS, Appellant v.

SEAN MICHAEL MCGUIRE, Appellee __________________________ APPELLEE’S MOTION FOR EXTENSION OF TIME ______________________________ TO THE HONORABLE JUSTICES OF THE FIRST COURT OF

APPEALS:

COMES NOW, Sean Michael McGuire, 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, Appellee would show this Honorable Court the

following:

1. Appellee’s brief is due in this case on July 10, 2015. ^[1]

2. Appellant seeks an extension of sixty days in which to file his brief, *2 making his brief due on or before September 9, 2015.

3. In the past thirty days, the undersigned has filed an appellate 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 appellate briefs in the

Thirteenth Court of Appeals in Cause Numbers 13-14-00547-CR; 13-14-00548-

CR; and 13-14-00549-CR; J ohn Steen v. The State of Texas . In addition, the

undersigned filed an appellate brief in the Fourth Court of Appeals in Cause

Number 04-14-00787-CR, Matthew Aranda v. The State of Texas . Further, the

undersigned drafted Proposed Findings of Fact and Conclusions of Law in the th District Court of Williamson County in Cause Number 13-0826-K277-CR,

The State of Texas v. Crispin James Harmel . Finally, the undersigned has made

numerous court appearances, has reviewed the Reporter’s Record in numerous

pending appellate cases, and has undertaken other tasks pertinent to the practice of

a solo attorney.

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 September 9, 2015.

PRAYER WHEREFORE, PREMISES CONSIDERED, Appellant respectfully

requests that this Court grant his Motion for Extension of Time.

Respectfully submitted, /s/ Kristen Jernigan State Bar No. 90001898

207 S. Austin Ave.

Georgetown, Texas 78626 (512) 904-0123 (512) 936-1650 (fax) Kristen@txcrimapp.com *3 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Appellant’s

Motion for Extension of Time has been mailed to the Fort Bend County District

Attorney’s Office on July 7, 2015.

/s/ Kristen Jernigan

[1] The State filed an amended brief on June 10, 2015.