No. 03

- 1 5

- 00 024

- CR

In the COURT OF APPEALS For the
T HIR D SUPREME JUDICIAL DISTRICT

at Austin

______________________________________ On Appeal from the 368th Judicial District Court of Williamson County, Texas Cause Number 13

- 0686

- K27 7

___________ ___________________________

STEVEN ROE , Appellant

v. THE STATE OF TEXAS, Appellee

_____________________________________

APPELLANT’S MOTION FOR EXTENSION OF TIME

______________________________

TO THE HONORABLE JUSTICES OF THE T HIR D COURT OF

APPEALS :

COMES NOW, Steven Roe , 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. Appell ant’s brief was due in this case on J une 8 , 2015

.

2. Appellant seeks an extension of sixty days in which to file his brief, making his brief due on or before August 7 , 2015

.

3

. In the past thirty days, the undersigned has filed a brief in the
F ourteenth Court of Appeals in C ause Number 14

- 15

- 00030

- CR, Miguel Macias v. The State of Texas

. The undersigned also filed a brief in the Seventh Court of Appeals in Cause Number 07

- 15

- 00016

- CR, Lawrence Williams Pena v. The State ACCEPTED 03-15-00024-CR 5653761 THIRD COURT OF APPEALS

AUSTIN, TEXAS 6/12/2015 11:13:16 AM JEFFREY D. KYLE

CLERKof Texas . The undersigned filed a brief in the Fourth Court of Appeals in Cause Number 04

- 14

- 00787

- CR, Matthew Aranda v. The State of Texas

. In addition, the undersigned is currently drafting a brief in the Cause Number 01

- 14

- 00641

- CR, Cornelius Milan Harper v. The State of Texas , which is a capital murder c ase in which the record consists of seventy

- one volumes

. Further, the undersigned was counsel of record in a hearing on an Application for Writ of Habeas Corpus based on Double Jeopardy Grounds in Cause Number 13

- 0826

- K277, The State of Texas v. Crispin Ha rmel , in which multiple witnesses were called and evidence was submitted. Finally, the undersigned has made numerous court appearances and has undertaken the tasks associated with the management of a solo attorney practice.

4

. The undersigned has not fil ed any previous motions for extension of time in this case.

5

. For the reasons set forth above, Appellant respectfully requests that he b e granted an extension of sixty days so that his brief in this case will now be due

on August 7 , 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 78 626 ( 512) 904

- 0123 (512) 452

- 1382 (fax) Kristen@txcrimapp.com2 CERTIFICATE OF SERVICE

The undersigned hereb y certifies that a true and correct copy of the

foregoing Appellant’s Motion for Extension of Time has been e mailed to John C.

Pre zas, Appellate Attorney for the Williamson County District Attorney’s Office,

at jprezas@wilco.org on June 12 , 2015

.

__ /s/ Kristen Jernigan

___ _

______________ Kristen Jernigan