NO. 01- 14 -00493- CR

IN THE COURT OF APPEALS

OF TEXAS

FIRST SUPREME JUDICIAL DISTRICT

LUIS RUIZ SIERRA, APPELLANT

VS.

STATE OF TEXAS, APPELLEE



### MOTION FOR EXTENSION OF TIME

WITHIN WHICH TO FILE APPELLANT ’S BRIEF

TERRENCE GAISER

LAWYER FOR APPELLANT

2900 SMITH STREET, # 220

HOUSTON, TEXAS 77006

SBOT# 07572500

713/ 225-0666

tagaiser@aol.com ACCEPTED

01-14-00493-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

9/18/2015 12:36:05 PM

CHRISTOPHER PRINE

CLERK1 NO. 1396147

STATE OF TEXAS § IN THE DISTRICT COURT

§

VS. § HARRIS COUNTY,TEXAS

§

LUIS RU IZ SIERRA § 182ND JUDICIAL DISTRICT

MOTION FOR EXTENSION OF TIME

WITHIN WHICH TO FILE APPELLANT’S BRIEF

NOW COMES LUIS RUIZ SIERRA, appellant in the above

captioned cause, by and through his attorney, TERRENCE GAISER, and

files his Motion for Extensio n of time within which to file Appellant’s Brief;

for which he would show:

1) This is an appeal from a conviction for the offense of burglary of a

habitation with the intent to commit the felony of sexual assault.

Punishment was assessed at thirty years confi nement. Notice of appeal

and the certification of appellant’s right to appeal were timely filed.

2) This is the first requested extension of time. The brief was due

September 4, 2015.

3) Appellant would request an extension of time to file the brief to a nd

including the 28h day of September, 2015.

4) For good cause counsel for the appellant would show that he has not had

time to complete the brief in this cause for the following reasons:2

b) Counsel has been in the criminal courts of the State of Te xas in Harris

County, Texas, and surrounding counties on a daily basis since the inception

of this appeal as follows:

08/04/15 County Court 10 State v. Frazier Assault

08/04/15 351 st District Court State v. Robinson PCS

08/05/15 337 th District Cour t State v. Kizzee Agg.Robb.

08/06/15 178 th District Court State v. Denkins Capital Murder

08/06/15 185 th District Court State v. Denkins Capital Murder

08/07/15 185 th District Court State v. Denkins Capital Murder

08/10/15 351 st District Court State v. R uiz

- Navarro IDFraud

08/11/15 174 th District Court State v. Scott Agg.Asslt.

08/11/15 174 th District Court State v. Rodriguez Theft

08/11/15 248 th District Court State v. Gunter PCS

08/12/15 351 st District Court State v. Haywood Agg.Sex.Asslt.

0 8/12/15 228 th District Court State v. Amaya Tampering

08/12/15 179 th District Court State v. Rhine Agg.Robb.

08/13/15 179 th District Court State v. Omarmustafa Agg.Asslt.

08/13/15 262 nd District Court State v. Garcia Ag.Robb.

08/13/15 337 th District Co urt State v. Kizzee Agg.Robb.

08/14/15 County Court 12 State v. Marhofer DWI3

08/14/15 351 st Distict Court State v. Haywood Ag.Sex.Asslt.

08/17/15 230 th District Court State v. Jackson Injury to Child

08/18/15 230 th District Court State v. Jackso n Injury to Child

08/18/15 176 th District Court State v. Cooper Eng.Org.Crim.Act.

08/18/15 232 nd District Court State v. Nizon Agg.Robb,

08/18/15 232 nd District Court State v. Muscovalley Evading

08/18/15 179 th District Court State v. Rhine Agg.Robb

.

08/19/15 339 th District Court State v. Tornes

- Navarro IDFraud

08/19/15 351 st District Court State v. Robinson PCS

08/20/15 178 th District Court State v. Banks Robb.

08/20/15 178 th District Court State v. Rodriguez Capital Murder

08/20/15 179 th Dist rict Court State v. Nagel PCS

08/20/15 179 th District Court State v. Rhine Agg.Robb.

08/21/15 County Court 13 State v. Ospina FalseRept.

08/25/15 177 th District Court State v. Lee Arson

08/25/15 174 th District Court State v. Drayton Cap.Murder

08 /25/15 228 th District Court State v. Mason Cap.Murder

08/26/15 182 nd District Court State v. Murdie PCS

08/26/15 174 th District Court State v. Martinez DWI

08/26/15 351 st District Court State v. Robinson PCS4

08/27/15 177 th District Court State v. Ja cobs Sx.Asslt.Ch.

08/27/15 351 st District Court State v. Batts Agg.Asslt.

08/28/15 174 th District Court State v. Martinez DWI

09/02/15 263 rd District Court State v. Morris Agg.Robb

09/03/15 174 th District Court State v. Perez Burg.Hab.

09/03/15 174 th District Court State v. Moore Burg.Hab.

09/08/15 351 st District Court State v. Robinson PCS

09/08/15 351 st District Court State v. Casiano Agg. Asslt.

09/09/15 263 rd District Court State v. Morris Agg. Robb.

09/10/15 263 rd District Court State v. Ly ons Agg. Robb.

09/11/15 351 st District Court State v. Casiano Agg. Asslt.

09/11/15 174 th District Court State v. Perez DWI

09/14/15 351 st District Court State v. Casiano Agg. Asslt.

09/14/15 351 st District Court State v. Haywood Agg.Sx.Asslt.

09/16/15 262 nd District Court State v. Garcia Agg.Asslt.

09/17/15 174 th District Court State v. Stevens Burg.Hab.

09/17/15 174 th District Court State v. Scott Agg.Asslt.

09/17/15 174 th District Court State v. Rodriguez Theft

09/17/15 179 th District Co urt State v. Omarmustafa Agg.Asslt.

Counsel has other cases in other counties not included in this list.5

d) Counsel filed the brief in Derrick Deshawn Gilbert, Cause Number 01

- 15

-

00144, in this Court on Septermber 8, 2015

e) Counsel has other briefs due in this Court and the 14 th Court that he

is trying to complete.

WHEREFORE, PREMISES CONSIDERED, Appellant prays for an

extension of time to file the Appellant’s Brief to and including September

28, 2015.

RESPECTFULLY SUBMITTED,

S/Terrence A. Gaiser

TE RRENCE A. GAISER

LAWYER FOR APPELLANT

2900 SMITH STREET, # 220

HOUSTON, TEXAS 77006

SBOT# 07572500

tagaiser@aol.com

CERTIFICATE OF SERVICE

I CERTIFY THAT A COPY OF THE ABOVE AND

FOREGOING MOTION FOR EXTENSION OF TIME WITHIN

WHICH TO FILE APPEL LANT’S BRIEF WAS SERVED ON ALL

PARTIES ACCORDING TO THE RULES.

S/Terrence A. Gaiser

TERRENCE A. GAISER