Rendon, Michael Eric ( 2015 )

PD-00013-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 4/2/2015 11:58:17 AM
April 2, 2015 Accepted 4/2/2015 12:49:22 PM
ABEL ACOSTA
NO.
00013-­‐15
CLERK
THE
STATE
OF
TEXAS
§
IN
THE
COURT
OF
V.
§
CRIMINAL
APPEALS
MICHAEL
ERIC
RENDON
§
AUSTIN,
TEXAS
APPELLEE’S
MOTION
FOR
AN
EXTENSION
OF
TIME
TO
FILE
APPELLEE’S
BRIEF
ON
STATE’S
PETITION
FOR
DISCRETIONARY
REVIEW
TO
THE
HONORABLE
COURT
OF
CRIMINAL
APPEALS:
Now
comes,
Edward
F.
Shaughnessy,
III,
attorney
at
law,
attorney
for
the
appellee,
Michael
Eric
Rendon,
and
files
this
Appellee’s
Motion
for
an
Extension
of
Time
to
File
Appellee’s
Brief
on
State’s
Petition
for
Discretionary
Review.
In
support
of
the
instant
motion
the
Appellee
would
show
unto
the
court
the
following:
A.
The
appellant
was
charged
by
way
of
indictments
returned
by
a
Victoria
County
grand
jury
with
the
offenses
of
Money
Laundering
and
Possession
of
a
Marijuana
in
cause
numbers
12-­‐8-­‐26805-­‐D
&
12-­‐8-­‐
0026806-­‐D.
Following
a
pre-­‐trial
motion
to
suppress
evidence
the
trial
Court
entered
an
order
granting
the
defendant’s
motion
to
suppress.
Notice
of
appeal
was
filed
by
the
State
of
Texas
and
an
appeal
was
pursued
to
the
Court
of
Appeals.
The
judgment
of
the
trial
Court
was
affirmed
on
direct
appeal
and
a
petition
for
discretionary
review
was
granted
to
the
State
of
Texas.
The
State’s
brief
was
filed
in
this
Court
on
March
3’
2015.
The
appellee’s
brief
is
due
to
be
filed
with
this
Court
on
April
2,
2015.
The
appellee
respectfully
requests
a
thirty
day
extension
of
time
to
file
the
appellee’s
brief
until
May
2,
2015.
B.
The
appellee
is
seeking
an
extension
of
time
to
file
the
instant
for
the
first
time;
no
previous
extensions
of
time
have
bee
sought
by
the
appellee.
C.
The
undersigned
counsel
is
representing
the
appellee
in
this
matter
without
having
previously
been
involved
in
this
matter.
The
undersigned’s
representation
originated
with
the
filing
of
the
appellant’s
brief
in
this
Court.
D.
The
undersigned
is
presently
in
the
process
of
compiling
briefs
on
the
behalf
of
the
State
of
Texas
in
the
cases
of
Jennifer
Pena
v.
The
State
of
Texas,
Cause
no.
13-­‐14-­‐00291-­‐CR;
Felix
Villarreal
v.
The
State
of
Texas,
Cause
no.
13-­‐15-­‐00014-­‐CR
and
Chad
Ballard
v.
The
State
of
Texas,
Cause
No.
04-­‐14-­‐00603-­‐CR.
In
addition
the
undersigned
is
in
the
process
of
filing
briefs
on
behalf
of
the
appellant
in
the
cases
of
Jordan
Lewis
v.
The
State
of
Texas,
Cause
no.
01-­‐14-­‐00557-­‐CR.
E.
Counsel
has
recently
filed
briefs
on
behalf
of
the
appellee
in
the
cases
of
Lawrence
Steele
Terrill
v.
The
State
of
Texas,
Cause
No.
04-­‐14-­‐
00571-­‐CR
and
Edgar
Javier
Gonzales
v.
The
State
of
Texas,
Cause
No.
04-­‐14-­‐00100-­‐CR.
F.
The
undersigned
recently
filed
a
brief
on
behalf
of
the
appellant
in
the
case
of
Ex
Parte
Greg
Saul,
Cause
Number
04-­‐15-­‐00093-­‐CR.
G.
Counsel
is
scheduled
to
begin
a
jury
trial
in
the
290th
District
Court
of
Bexar
County
on
April
6,
2015
in
the
case
of
The
State
of
Texas
v.
Roland
Aguiar,
cause
no.
2014-­‐CR-­‐10164
wherein
the
defendant
is
charged
with
the
offense
of
Murder.
CONCLUSION
AND
PRAYER
Wherefore
premises
considered
the
appellee
in
the
instant
case
would
respectfully
request
that
this
Court
grant
the
instant
motion
and
extend
the
time
for
the
filing
of
the
appellee’s
brief
until
May
4,
2015.
___/s/Edward F. Shaughnessy___________
Edward
F.
Shaughnessy,
III
206
E.
Locust
San
Antonio,
Texas
78212
(210)
212-­‐6700
(210)
212-­‐2178
(fax)
SBN
18134500
Shaughnessy727@gmail.com
CERTIFICATE
OF
SERVICE
I,
Edward
F.
Shaughnessy,
III,
hereby
certify
that
a
true
and
correct
copy
of
the
instant
motion
was
mailed
to
Stephen
B.
Tyler,
attorney
for
the
appellant
at
205
N.
Bridge
St.
Suite
301,
Victoria,
Texas
77901,
on
this
the
31st
day
of
March,
2015.
__/s/Edward F. Shaughnessy______
Edward
F.
Shaughnessy,
III