David Patrick Bertram v. State ( 2018 )

ACCEPTED
01-17-00940-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/20/2018 3:26 PM
CHRISTOPHER PRINE
CLERK
NOS. 01-17-00940-CR
IN THE COURT OF APPEALS FILED IN
FOR THE FIRST DISTRICT OF TEXAS 1st COURT OF APPEALS
HOUSTON, TEXAS
3/20/2018 3:26:02 PM
CHRISTOPHER A. PRINE
DAVID BERTRAM Clerk
Appellant
v.
THE STATE OF TEXAS
Appellee
On Appeal from Cause Number 1519159
From the 178th District Court of Harris County, Texas
APPELLANT’S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE AN
APPELLATE BRIEF
To the Honorable Court of Appeals of Texas:
Comes now Appellant, in accordance with Rules 10.5(b)(1) and 38.6(d) if the
Texas Rules of Appellate Procedure, and files this motion for extension of time in
which to file the Appellant’s brief in this cause and, in support thereof, presents the
following:
1. In the 178th District Court of Harris County, Texas, following a jury trial,
Appellant was found guilty on November 29, 2017, in Cause Number 1519159,
The State of Texas v. David Bertram for Attempted Aggravated Kidnapping
and sentenced to 50 years in the Institutional Division of the Texas
Department of Criminal Justice on each count.
2. A written notice of appeal was timely filed on November 29, 2017.
3. The Appellant’s brief is due on March 19, 2018.
4. Appellant requests an extension of time in which to file his brief until April 20,
2018.
5. No prior extensions have been requested or granted.
6. The facts relied upon to explain the need for this extension are:
a. Appellant’s counsel requires additional time to adequately research the
issues in this case and write a brief on his behalf.
Consequently, additional time will be necessary in which to file Appellant’s
brief in this case. The Appellant’s motion is not for purposes of delay, but so that
justice may be done.
WHEREFORE, the Appellant Prays that this Court will grant an additional
extension of time until April 20, 2018, in which to file Appellant’s brief in this case.
Respectfully submitted,
_s/Tonya Rolland
Tonya Rolland
1225 N Loop W, Suite 640
Houston, Texas 77008
Phone: (713) 529-8500
Fax: (713) 453-2203
TBN 24054176
tonya@rollandlaw.com
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CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing instrument has been delivered via
e-service to the following:
mccrory_daniel@dao.hctx.net
Assistant District Attorney
Harris County District Attorney’s Office
Houston, Texas 77002
_s/Tonya Rolland
Tonya Rolland
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