No. 14-15-00030-CR

In the

COURT OF APPEALS

For the

FOURTEENTH SUPREME JUDICIAL DISTRICT

at Houston

______________________________________

On Appeal from the 427th District Court of

Travis County, Texas

Cause Number D-1-DC-13-30173

______________________________________

MIGUEL MACIAS, Appellant

v.

THE STATE OF TEXAS, Appellee

_____________________________________

APPELLANT’S MOTION FOR EXTENSION OF TIME

______________________________

TO THE HONORABLE JUSTICES OF THE FOURTEENTH COURT OF 

APPEALS:

COMES NOW, Miguel Macias, 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 is due in this case on April 17, 2015.

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

making his brief due on or before June 16, 2015.

3. On March 16, 2015, the undersigned sent a written request for the 

clerk’s record and reporter’s record on disk, along with a check for $1.00 and a 

stamped, self-addressed envelope, as directed by the Clerk’s Office. The request 

informed this Court that the undersigned is Court-appointed. To date, the 

ACCEPTED

14-15-00030-CR

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

4/17/2015 4:02:27 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 4/17/2015 4:02:27 PM CHRISTOPHER A. PRINE Clerk
undersigned has not received the clerk’s record or the reporter’s record from this 

Court.

4. In the past thirty days, the undersigned has filed a brief in the 

Fourteenth Court of Appeals in Cause Number 14-15-00053-CR, Joseph Henry 

Edward Haynes v. The State of Texas. The undersigned filed a brief in the Third 

Court of Appeals in Cause Number 03-14-00599-CR, Timothy Colt Castleberry v. 

The State of Texas. Additionally, the undersigned filed a letter brief in the Tenth 

Court of Appeals in Cause Number 10-14-00227-CR, Pedro Rodriguez, Jr. v. The 

State of Texas. Further, the undersigned filed a Response to the State’s Petition 

for Petition for Discretionary Review in Cause Number PD-0280-15, The State of 

Texas v. John Allen Wachtendorf. Moreover, the undersigned filed a 

Supplemental Memorandum in Support of Habeas Corpus Relief in 

WR-82,426-02, Ex parte Robert Jesse Padilla, Jr. Finally, the undersigned has 

made numerous court appearances and has undertaken the tasks associated with the 

management of a solo attorney practice.

5. The undersigned has not filed any previous motions for extension of 

time in this case.

6. 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 June 16, 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) 931-3650 (fax)

Kristen@txcrimapp.com
2

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 mailed to the Travis 

County District Attorney’s Office, P.O. Box 1748, Austin, Texas 78767 on April 

17, 2015.

__/s/ Kristen Jernigan__________________

Kristen Jernigan