Arrington, Charles

Opinion

PD-0756-15

PD-0756-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS

Transmitted 6/19/2015 3:17:27 PM Accepted 6/24/2015 9:40:48 AM No.___________________ ABEL ACOSTA CLERK

CHARLES LAVOY ARRINGTON § IN THE TEXAS COURT § OF CRIMINAL APPEALS STATE OF TEXAS § AUSTIN, TEXAS

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

From the 187th District Court of Bexar County, Texas Trial Court Nos. 2011- CR-1663 Hon. Sharon McRae, Visiting Judge Presiding

In accordance with Tex. R. App. Pro. 68.2, the undersigned counsel submits his “Unopposed Motion for Extension of Time to File Petition for Discretionary Review,” and shows as follows:

The Fourth Court of Appeals denied Appellant’s motions for rehearing, and for rehearing en banc, on May 21, 2015.

In the interim, Counsel has prepared and filed a motion for rehearing, on an affirmance after remand, in Villarreal v. State, 2015 Tex. App. LEXIS 2758 (Tex. App. San Antonio Mar. 25, 2015), before the Fourth Court of Appeals of Texas, on Tuesday, June 9, 2015, which is pending before said Court;

Counsel prepared for, and was set for trial in State v. Hernandez, Cause No. 442924, on Monday, June 15, 2015, in County Court at Law # 9, involving a DWI > .15 BAC charge. In lieu of proceeding with jury selection, the case was resolved by dismissal, and plea to an Obstruction of a Highway, that same day;

Counsel filed an amended brief in State of Texas v. Luis Arnaldo Baez, No.

04-14-00374-CR, with the San Antonio, Fourth Court of Appeals, on Tuesday, June 16, 2015;

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June 24, 2015

Counsel has slotted a vacation with his family, beginning Tuesday, June 23, to Wednesday, July 1, 2015.

Ms. Lauren Scott, Assistant District Attorney in charge of this case has expressed that he is not opposed to the requested extension, as communicated to the undersigned via email communication on Friday, June 19th, 2015.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this Court grant a 30-day extension of time to file his petition for discretionary review, from Monday, June 22nd, 2015, to, and including Wednesday, July 22nd, 2015.

Respectfully submitted,

Jorge G. Aristotelidis

Tower Life Building

310 South St. Mary’s Street, Suite 1830 San Antonio, Texas 78205

(210) 277-1906

jgaristo67@gmail.com

By: /s/ JORGE G. ARISTOTELIDIS SBN: 00783557

Attorney for Petitioner

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CERTIFICATE OF SERVICE

I hereby certify that on this the 19th day of June, 2015 a copy of the foregoing “Unopposed Motion for Extension of Time to File Petition for Discretionary Review” has been delivered to the Appellate Section of the Bexar County District Attorney’s Office, via electronic filing.

/s/ JORGE G. ARISTOTELIDIS