Case Information

*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 11/18/2015 11:16:32 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-15-00033-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 11/18/2015 11:16:32 AM CHRISTOPHER PRINE CLERK NO. 14-15-00033-CR IN THE COURT OF APPEALS FOURTEENTH DISTRICT OF TEXAS

HOUSTON, TEXAS LINDA WOODMAN § APPELLANT

VS. §

THE STATE OF TEXAS § APPELLEE APPEAL FROM THE 147 TH JUDICIAL DISTRICT COURT

TRAVIS COUNTY, TEXAS CAUSE NO. D1-DC-14-904029 STATE'S SECOND MOTION FOR EXTENSION OF TIME

TO THE HONORABLE COURT OF APPEALS:

The State of Texas respectfully moves for an extension of the deadline for

filing the State’s brief and, in accordance with Texas Rules of Appellate Procedure

38.6 and 10.5(b), advises the Court as follows:

(a) Following her conviction for Aggravated Assault with a Deadly Weapon,

the appellant filed her notice of appeal in the above cause on November 25, 2014.

Appellant filed a brief on September 17, 2015.

(b) The State’s brief is currently due on November 18, 2015 .

(c) This request is that the deadline for filing the State’s brief be extended

by 20 days .

(d) The number of previous extensions of time granted for submission of

the State’s brief is: one .

(e) The State relies upon the following facts to reasonably explain the

need for an extension of the deadline:

1. During the period since the appellant’s brief was filed, the

undersigned attorney has completed and filed an original brief in

another pending appellate case, (i.e. Thomas Joseph Krausz v.

State of Texas, No. 03-15-00110-CR). The undersigned attorney

is also responsible for preparing the State’s brief in two other

pending appellate cases (i.e. DeAndre Dwight Joseph aka

Deandre Dwight Parks v. State of Texas, No. 03-15-00209-CR;

and Linda Woodman v. State of Texas, No. 14-15-00032-CR).

2. The undersigned attorney’s mother had a heart attack on

November 11, 2015, and was scheduled for bypass surgery on

Monday, November 16, 2015. The undersigned attorney traveled

to San Antonio, Texas to be with her mother during her surgery

and recovery.

3. This request is not made for the purpose of delay, but to ensure

that the Court has a proper State’s brief to aid in the just

disposition of the above cause.

WHEREFORE, the State of Texas respectfully requests that the deadline for

filing the State’s brief be extended to December 8, 2015.

Respectfully submitted, ROSEMARY LEHMBERG District Attorney Travis County, Texas /s/ Lisa Stewart Lisa Stewart Assistant District Attorney State Bar No. 06022700 P.O. Box 1748 Austin, Texas 78767 (512) 854-9400 Fax No. 854-4810 Lisa.Stewart@traviscountytx.gov AppellateTCDA@traviscountytx.gov *4 CERTIFICATE OF COMPLIANCE

Pursuant to Texas Rule of Appellate Procedure 9.4(i), I hereby certify, based

upon the computer program used to generate this motion, that this motion contains

310 words, excluding words contained in those parts of the motion that Rule 9.4(i)

exempts from inclusion in the word count. I certify, further, that this motion is

printed in a conventional, 14-point typeface.

/s/ Lisa Stewart Lisa Stewart Assistant District Attorney CERTIFICATE OF SERVICE I hereby certify that, on the 18 th day of November, 2015, a true and correct

copy of this motion was served, by U.S. mail, electronic mail, facsimile, or

electronically through the electronic filing manager, to the Appellant’s attorneys,

Steven Brand, Fagerberg, Arana & Brand, P.C., 907 Rio Grande Street, Austin,

Texas 78701, stevenbrand@rocketmail.com; and Linda Icenhauer-Ramirez,

Attorney at Law, 1103 Nueces, Austin, Texas 78701, ljir@aol.com.

/s/ Lisa Stewart Lisa Stewart Assistant District Attorney