John Gabriel Esquivel v. State ( 2015 )


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  •                                                                                                            ACCEPTED
    03-15-00439-CR
    8152203
    THIRD COURT OF APPEALS
    AUSTIN, TEXAS
    12/9/2015 10:05:26 AM
    JEFFREY D. KYLE
    CLERK
    CAUSE NO. 03-15-00439-CR
    JOHN GABRIEL ESQUIVEL                          §              IN THE THIRD COURT
    Appellant,                                §                                FILED IN
    3rd COURT OF APPEALS
    §                              AUSTIN, TEXAS
    §                         12/9/2015 10:05:26 AM
    v.                                             §              OF APPEALS
    JEFFREY D. KYLE
    §                                  Clerk
    THE STATE OF TEXAS                             §
    Appellee,                                 §              STATE OF TEXAS
    SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF
    TO THE HONORABLE JUDGE OF SAID COURT:
    NOW COMES JOHN ESQUIVEL, Appellant, by and through their attorney, Amber
    Vazquez Bode, and file this Second Motion for Extension of Time to File Appellant's Brief.
    In support thereof Appellant offers as follows:
    1.      According to the Texas Rules of Appellate Procedure Rule 38.6 Time to File
    Briefs:
    "(a) Appellant's Filing Date.        Except in a habeas corpus or bail appeal, which is
    governed by Rule 31, an appellant must file a brief within 30 days-20 days in an accelerated
    appeal-after the later of:
    ( 1)     The date the clerk's record was filed; or
    (2)      The date the reporter's record was filed."
    2.       The Reporter's Record was filed on October 8, 2015.
    3.      The appellant's brief is due on December 9, 2015.
    4.      The Appellant cites the following facts and reasons to the Court as Justification
    for this Second Motion for Extension:
    a) Counsel just got out of a felony trial on December 3, 2015 in the 368th District
    Court in Williamson County Texas, Cause No. 14-1915-K368. Furthermore counsel
    is needing an extension to gather research and was unable to gather all research due to   '
    the felony trial last week.
    5.       Appellant hereby requests an extension of 30 days due to the stated reasons.
    6.       Appellant respectfully requests a brief extension of 30 days in order to receive
    proper research for the case.
    The Appellant respectfully requests that this court GRANT the Second Motion for
    Extension of Time to File Appellant's Brief.
    R
    A        azquez Bode
    State Bar No. 24039225
    The Vazquez Law Firm
    1004 West Ave.
    Austin, Texas 78701
    (512) 220-8507 (telephone)
    (512) 480-0760 (facsimile)
    COUNSEL FOR APPELLANT
    CERTIFICATE OF SERVICE
    I, AMBER VAZQUEZ BODE, Attorney for Appellant, do hereby certify that a true and
    correct copy of the above and foregoing Second Motion for Extension of Time to File
    Appellant's Brief has been served electronically on
    Third Court of Appeals
    Price Daniel Sr. Bldg.
    209 West 14th Street, Room 101
    Austin, Texas 78701
    Ms. Angela Chambers
    299th District Court
    Official Court Reporter
    299th Judicial District Court
    Blackwell-Thurman Justice Center
    509 West 11th Street- 8th Floor
    Austin, Texas 78701
    Travis County District Attorney
    Appellate Division
    509 West 11th Street
    Austin, Texas 78701
    Travis Count~ District Clerk
    509 West 11 t Street, Room 1.400
    Austin, Texas 78701
    The Honorable Karen Sage
    299th District Court
    Blackwell-Thurman Justice Center
    509 West 11th Street- 8th Floor
    Austin, Texas 78701
    

Document Info

Docket Number: 03-15-00439-CR

Filed Date: 12/9/2015

Precedential Status: Precedential

Modified Date: 9/30/2016