Case Information

*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 9/2/2015 11:54:39 AM JEFFREY D. KYLE Clerk No. 03-15-000222-CR THIRD COURT OF APPEALS 9/2/2015 11:54:39 AM JEFFREY D. KYLE AUSTIN, TEXAS 03-15-00222-CR *1 ACCEPTED ^[6761839] CLERK

In the

COURT OF APPEALS

For the

THIRD SUPREME JUDICIAL DISTRICT

at Austin

______________________________________

On Appeal from the 277th Judicial District Court of

Williamson County, Texas

Cause Number 13-1923-K277

______________________________________

MONTE KEN ROSS, Appellant

v.

THE STATE OF TEXAS, Appellee

_____________________________________

APPELLANT’S MOTION FOR EXTENSION OF TIME

______________________________

TO THE HONORABLE JUSTICES OF THE THIRD COURT OF

APPEALS:

COMES NOW, Monte Ken Ross, 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 August 25, 2015.

2. Appellant seeks an extension of sixty days in which to file his brief,

making his brief due on or before October 24, 2015. In the next thirty days, the undersigned is preferentially set in a

murder trial in the 21 st District Court of Bastrop County in Cause Number 15,605,

The State of Texas v. Daniel Willis . The trial is expected to last two weeks. In

addition, the undersigned is set for a hearing in the 434 th District Court in Cause

Number 11-DCR-56513, The State of Texas v. Cornelius Milan Harper . This is a

capital murder case in which there are serious omissions and misstatements in the

Reporter’s Record which requires the undersigned to review eighteen volumes of

the record before September 9, 2015. Finally, the undersigned has a brief due in

the First Court of Appeals in the case of Sean McGuire v. The State of Texas , No.

01-14-00123-CR. The undersigned has filed one previous motion 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 October 24, 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) 452-1382 (fax) Kristen@txcrimapp.com *3 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 emailed to John C.

Prezas, Appellate Attorney for the Williamson County District Attorney’s Office,

at jprezas@wilco.org on September 2, 2015.

__/s/ Kristen Jernigan__________________ Kristen Jernigan

2