Case Information

*0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 12/23/2015 1:21:22 PM JEFFREY D. KYLE Clerk IN THE THIRD COURT OF APPEALS THIRD COURT OF APPEALS 12/23/2015 1:21:22 PM JEFFREY D. KYLE AUSTIN, TEXAS 03-15-00273-CR *1 ACCEPTED ^[8361179] CLERK AT AUSTIN, TEXAS CHRISTOPHER TREMANE §

SAUNDERS, §

Appellant §

§ CAUSE NO. 03-15-00273-CR V. § TRIAL COURT NO. 68919

§

THE STATE OF TEXAS, §

Appellee §

MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

NOW COMES CHRISTOPHER TREMANE SAUNDERS,

Appellant in the above styled and numbered cause, by and through Counsel,

and moves this Court to grant an extension of time to file appellant’s brief,

pursuant to Rule 38.6(d) of the Texas Rules of Appellate Procedure , and

for good cause shows the following:

1. This case is on appeal from the 27 District Court in Bell County,

Texas.

2. The case below is styled The State of Texas v. Christopher

Tremane Saunders and numbered 68919.

3. Appellant was convicted of injury to a child, elderly or disabled

individual. Appellant was assessed a sentence of six (6) year’s incarceration

in the Institutional Division of the Texas Department of Criminal Justice on

April 30, 2015.

4. Notice of appeal was given on April 30, 2015.

5. The Clerk’s and Reporter’s records were filed on June 30, 2015

and November 24, 2015, respectively.

6. The Appellant’s brief is presently due on December 24, 2015.

7. Appellant requests an extension of time to file Appellant’s brief of

30 days from December 24 date until January 24, 2016.

8. No previous requests for extension to file the brief have been filed

in this cause.

9. Defendant is currently incarcerated.

Appellant relies on the following facts as good cause for the requested

extension: Besides Counsel’s normal workload, on December 14, 2015,

Counsel for appellant completed and filed a brief in a non-death penalty

capital case, to-wit: Boswell v. State , No. 03-15-00540-CR. The reporter’s

record in that case consisted of 12 volumes covering, with various pre-trial

hearings, a week-long trial. Immediately following that, Counsel was out of

her office for approximately 4 working days including over-night stays in

connection with other legal matters. Finally, Counsel had planned vacation

time during the Christmas holidays from the 23 rd of December until the 4 of

January, 2016. The undersigned, therefore, would request an additional 30

days from December 24, 2015, to review the record and to perform the

necessary legal research for preparation of the brief herein.

WHEREFORE, Appellant prays that this Court grant this Motion to

Extend Time to File Appellant’s Brief, and for such other and further relief

as the Court may deem appropriate.

Respectfully submitted, COPELAND LAW FIRM P.O. Box 399 Cedar Park, TX 78613 Mobil/Text: 512.897.8126 Fax: 512-215-8114 Email: ecopeland63@yahoo.com By: /s/ Erika Copeland Erika Copeland State Bar No. 16075250 Attorney for Appellant CERTIFICATE OF SERVICE AND OF COMPLIANCE WITH RULE 9 This is to certify that on December 22, 2015, a true and correct copy

of the above and foregoing document was served on Henry L. Garza,

District Attorney, Attn: Bob Odom, Appellate Division, PO Box 324,

Belton, TX 76513-0324, and that this Motion to Extend Time to File

Appellant’s Brief is in compliance with Rule 9 of the Texas Rules of

Appellate Procedure and that portion which must be included under Rule

9.4(i)(1) contains 541 words. A conference with opposing counsel was held

on December 23, 2015, and opposing party does not oppose said motion.

/s/ Erika Copeland Erika Copeland