Derrick Kuykendall v. State ( 2015 )

ACCEPTED 03-14-00531-CR 7442430 THIRD COURT OF APPEALS AUSTIN, TEXAS 10/19/2015 5:01:09 PM JEFFREY D. KYLE CLERK NO. 03-14-00531-CR DERRICK KUYKENDALL * IN THE COURT OF APPEALS FILED IN 3rd COURT OF APPEALS Appellant * AUSTIN, TEXAS 10/19/2015 5:01:09 PM VS. * OF THE THIRD JEFFREY D. KYLE Clerk * SUPREME JUDICIAL * DISTRICT OF TEXAS THE STATE OF TEXAS * Appellee * AT AUSTIN TEXAS MOTION FOR EXTENSION OF TIME TO FILE APPELLATE BRIEF TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: COMES NOW, Appellant, and files this Motion for an Extension in which to file the Appellant’s Brief. In support of this motion, appellant shows the Court the following: I. The Appellant was convicted in the District Court of Travis County, Texas of the offense of Manslaughter. After a probation revocation hearing, Appellant was assessed 15 years TDCJ. II. The deadline for filing the Appellant’s Brief is October 19, 2015 and Appellant has requested three previous extensions. III. Attorney for the Appellant would further show the Court that he has been diligent in preparing Appellee’s brief in this case. Due to a very busy docket counsel is unable to complete the brief within the time frame. Counsel requests an extension of time so that he may adequately prepare Appellant’s Brief. Counsel has completed his review of the brief and is currently researching and drafting. WHEREFORE, Appellant prays the Court grant this Motion and extend the deadline for filing the Appellant’s Brief to December 14, 2015. Respectfully Submitted, ARIEL PAYAN Attorney at Law 1012 Rio Grande Austin, Texas 78701 (512) 478-3900 (512) 472-4102 (fax) Arielpayan@hotmail.com /s/ Ariel Payan ARIEL PAYAN State Bar No. 00794430 CERTIFICATE OF SERVICE By my signature above, I hereby certify that a true and correct copy of the above and foregoing Motion for Extension of Time to File Appellate Brief has been delivered to the Criminal District Attorney of said County Texas, on October 19, 2015.