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No. 01-15-00134-CR

JENNIFER LEANN WATSON § IN THE COURT OF APPEALS 

 §

VS. § FOR THE FIRST DISTRICT

 §

THE STATE OF TEXAS § OF TEXAS

MOTION TO EXTEND TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT OF APPEALS:

COMES NOW Jennifer Leann Watson, Appellant, by and though her

undersigned attorney of record, and files this Motion to Extend Time to File 

Appellant’s brief herein, and as sufficient cause therefore shows the following 

facts within the personal knowledge of Appellant’s attorney:

I.

Appellant was indicted for the felony offense of Possession With Intent to 

Deliver a Controlled Substance. Appellant pled guilty and was placed on deferred 

adjudication community supervision for a period of three years. The State 

subsequently filed a motion to adjudicate guilt alleging that Appellant violated the 

conditions of her community supervision. Appellant pled true to the motion to 

adjudicate without any agreed recommendation from the State, and the trial court 

found Appellant guilty and sentenced her to serve six years in prison. Appellant 

filed timely written notice of appeal.

ACCEPTED

01-15-00134-CR

FIRST COURT OF APPEALS

HOUSTON, TEXAS

7/15/2015 7:26:50 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/15/2015 7:26:50 PM CHRISTOPHER A. PRINE Clerk
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II.

On June 17, 2015, Appellant’s attorney received notice from this Honorable 

Court of Appeals that Appellant’s first motion to extend time to file Appellant’s 

brief had been granted, making Appellant’s brief due on or before July 15, 2015.

III.

Appellant’s attorney hereby requests that the due date for Appellant’s brief 

be extended by a period of 30 days until August 14, 2015. This is Appellant’s

second request for an extension in this matter.

IV.

The facts relied upon to reasonably explain the need for the requested 

extension are as follows:

Appellant’s attorney is a solo practitioner who had a full schedule of court 

appearances on pending felony cases since June 15, 2015. In addition, during this 

same period Appellant’s attorney was involved in pre-trial preparations in five

pending felony trial cases, four of which were set for jury trial the week of July 6, 

2015. Further, Appellant’s attorney was involved in reviewing records and 

researching points of error in nine other pending direct appeals, including three 

with briefs filed the week of July 6, 2015. And finally, Appellant’s attorney was 

out of town on a previously scheduled family vacation for a period of two weeks. 
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Given the foregoing facts, Appellant’s attorney did not have adequate time 

available to properly review the appellate record, fully research potential points of 

error, and draft and file an appropriate appellate brief on Appellant’s behalf by the 

current due date of July 15, 2015.

WHEREFORE, ALL PREMISES CONSIDERED, Appellant prays that this 

Honorable Court of Appeals will grant this motion and extend the time to file 

Appellant’s brief for a period of 30 days to August 14, 2015.

Respectfully Submitted,

/s/ Randall J. Ayers

_________________________

Randall J. Ayers

Attorney for Appellant

State Bar #01465950

P.O. Box 1569

Houston, Texas 77251-1569

rjayerslaw@comcast.net (e-mail)

281-493-6333 (office)

281-493-9609 (fax)
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CERTIFICATE OF SERVICE

I certify that I served the foregoing motion on the District Attorney of Harris 

County, Texas, by sending a copy to Mr. Alan Curry, Chief of the Appellate 

Division, Harris County District Attorney’s Office, via electronic service to 

curry_alan@dao.hctx.net on July 15, 2015. 

/s/ Randall J. Ayers

_________________________

Randall J. Ayers

Attorney for Appellant

State Bar #01465950

P.O. Box 1569

Houston, Texas 77251-1569

rjayerslaw@comcast.net (e-mail)

281-493-6333 (office)

281-493-9609 (fax)

CERTIFICATE OF COMPLIANCE

Pursuant to the provisions of Rule 9(i)(3) of the Texas Rules of Appellate 

Procedure I certify that this document contains 601 words.

/s/ Randall J. Ayers

_________________________

Randall J. Ayers

Attorney for Appellant

State Bar #01465950

P.O. Box 1569

Houston, Texas 77251-1569

rjayerslaw@comcast.net (e-mail)

281-493-6333 (office)

281-493-9609 (fax)