IN THE THIRD COURT OF APPEALS 

FOR THE STATE OF TEXAS 

STATE OF TEXAS 

V. NO. 03-14-00547-CR

BRIAN ROLAND CHANDLER 

APPELLEE’S SECOND MOTION FOR

EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE THIRD COURT OF APPEALS: 

COMES NOW, Brian Roland Chandler, Appellee, by and through his attorney of 

record, Linda Icenhauer-Ramirez, and files this his Second Motion for Extension of Time 

to Brief and in support thereof, would show the Court the following: 

I.

That the above-styled and numbered cause is styled The State of Texas v. Brian 

Roland Chandler, Cause Number CR-12-0005 in the 428th Judicial District Court of 

Hays County, Texas. Appellant was sentenced on February 23, 2012. The trial court 

entered a judgment nunc pro tunc on August 7, 2014. 

II.

Appellee was convicted of one count of aggravated assault. His punishment was 

assessed at ten years imprisonment. The original judgment in the case said that appellee 

was found guilty of aggravated assault and contained an affirmative finding of a deadly 

weapon. Appellee filed a motion for a judgment nunc pro tunc deleting the deadly 

weapon finding. On August 7, 2014, the trial court held a hearing on the matter and after 

hearing the arguments of counsel and reviewing the record in the cause, granted 

appellee’s motion for judgment nunc pro tunc. 

ACCEPTED

03-14-00547-CR

4495126

THIRD COURT OF APPEALS

AUSTIN, TEXAS

3/13/2015 2:46:25 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 3/13/2015 2:46:25 PM JEFFREY D. KYLE Clerk
III.

The State filed its notice of appeal from this decision on August 7, 2014. The 

State filed its brief on December 9, 2014. The due date for appellee’s brief was January 

8, 2015. The attorney who represented appellee in the trial court informed appellee’s 

family that she does not practice appellate law and would not be able to represent 

appellee in the State’s appeal of this matter. The undersigned attorney was hired by 

appellee’s family and filed a notice of appearance in this matter on February 5, 2015.

IV.

This is Appellee’s second motion for extension of time to file his brief. Appellee

respectfully requests a thirty day extension of time to file the brief from today’s date, 

which would make such brief due on Saturday, April 12, 2015. The next working day is 

Monday, April 14, 2015. 

V.

The undersigned attorney was recently retained in this case. She has begun

researching the issues in this cause but due to appellate deadlines in other cases she has 

been unable to complete her research and file a response to the State’s brief. She 

recently completed and filed a supplemental brief in the case of In the Matter of J.M., 

Cause No. 03-14-00027-CV. She will be completing and filing a brief this next week in 

the case of Robert Ritz v. State of Texas, Cause No. 03-14-00403-CR. She has begun 

working on briefs in the cases of Leovardo Cantos, Cause No. 03-14-00585-CR and Troy 

Luther Williams v. State of Texas, Cause No. 03-14-00229-CR, both of which are due on 

April 9, 2015. The undersigned attorney asks that this extension be granted so that she 

may effectively represent Appellee and so that justice may be done in this case. 
 Respectfully Submitted,

/s/ Linda Icenhauer-Ramirez 

LINDA ICENHAUER-RAMIREZ

Attorney at Law

1103 Nueces

Austin, Texas 78701

(512) 477-7991

FAX #: (512) 477-3580

SBN: 10382944

EMAIL: ljir@aol.com

ATTORNEY FOR APPELLEE

CERTIFICATE OF COMPLIANCE

I hereby certify that this motion was computer generated and contains 613 words, 

as calculated by the word count function on my computer.

 /s/ Linda Icenhauer-Ramirez 

LINDA ICENHAUER-RAMIREZ

CERTIFICATE OF SERVICE

I, Linda Icenhauer-Ramirez, hereby certify that a true and correct copy of the 

foregoing Appellee’s Second Motion for Extension of Time to Brief was e-served to

Brian Erskine of the Hays County District Attorney's Office on this the 13th day of

March, 2015.

/s/ Linda Icenhauer-Ramirez 

LINDA ICENHAUER-RAMIREZ