Solis-Gonzalez, Luis ( 2015 )

WR-82,831-01
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 3/30/2015 4:01:00 PM
Accepted 3/30/2015 4:41:11 PM
ABEL ACOSTA
IN THE TEXAS COURT OF CRIMINAL APPEALS CLERK
RECEIVED
LUIS SOLIS GONZALEZ § COURT OF CRIMINAL APPEALS
§ 3/30/2015
ABEL ACOSTA, CLERK
v. § CASE NO. ___________________
§
STATE OF TEXAS §
MOTION FOR EXTENSION OF TIME TO FILE REPLY
TO WRIT OF MANDAMUS
TO THE HONORABLE JUDGE OF SAID COURT:
Comes now, Luis Solis Gonzalez, Petitioner in the above styled and numbered cause, and
files this First Motion for Extension of Time to File Reply to Writ of Mandamus, and would
show the Court as follows:
1. On January 9, 2015, the trial court ordered the Defendant to proceed to trial for a capital
offense in which the State is seeking the death penalty before the Texas Department of
Public Safety performs DNA tests of biological evidence collected as part of the
investigation for the offense.
2. Counsel for Defendant requests an extension of 14 days to file Petitioner’s Reply to Writ
of Mandamus. This is Petitioner’s first request for an extension of time in this case.
3. Petitioner relies on the following facts as a reasonable explanation for the requested
extension of time: Counsel needs additional time in order to prepare an adequate reply to
Writ of Mandamus.
4. This motion for an extension is not filed for the mere purposes of delay but so that justice
may be served.
Wherefore, premises considered, the undersigned requests that the Court grant this
Motion for Extension of Time for a period of 14 days from the date of filing.
Respectfully submitted,
JOE A. SPENCER
ATTORNEY AND COUNSELOR AT LAW
1009 Montana Ave.
El Paso, Texas 79902
(915) 532-5562
(915) 532-7535 fax
/s/
JOE A. SPENCER
State Bar No. 1892180
JOSHUA C. SPENCER
ATTORNEY AND COUNSELOR AT LAW
1009 Montana Ave.
El Paso, Texas 79902
(915) 532-5562
(915) 532-7535 fax
/s/
JOSHUA C. SPENCER
State Bar No. 24067879
CERTIFICATE OF SERVICE
The undersigned does hereby certify that a copy of the above motion was sent by hand delivery
to State’s Assistant District Attorney, Denise Butterworth and to the trial court: the Honorable
Luis Aguilar, 243rd District Court of El Paso County, Texas.
/s/
JOE A. SPENCER