Benny Cavazos Valverde v. State

Opinion

ACCEPTED 04-14-00338-CR Law Office of David A. Schulman Post Office Box 783 FOURTH COURT OF APPEALS Austin, Texas 78767 SAN ANTONIO, TEXAS Tel. 512-474-4747 Fax: 512-532-6282 No. 04-14-00338-CR 3/23/2015 12:07:59 PM KEITH HOTTLE CLERK IN THE COURT OF APPEALS FOR THE FOURTH JUDICIAL DISTRICT OF TEXAS, AT SAN ANTONIO Benny Cavazos Valverde, Appellant FILED IN 4th COURT OF APPEALS v. SAN ANTONIO, TEXAS 3/23/2015 12:07:59 PM The State of Texas, Appellee KEITHClerk E. HOTTLE

On Appeal in Case No. 2012CR3980, from the 290th District Court of Bexar County, the Hon. Melissa Skinner, Judge Presiding

Motion for Extension of Time To File Appellant's Brief on Appeal TO THE HONORABLE FOURTH COURT OF APPEALS: COMES NOW, Benny Cavazos Valverde, Appellant in the above styled and numbered cause (“Appellant”), by and through his retained counsel, David A. Schulman, his undersigned attorney of record, and respectfully enters this “Motion for Extension of Time to File Appellant's Brief on Appeal,” and in support of such Motion would show the Court:

I

Appellant was convicted of the offense of murder in the 290th District Court of Bexar County, then timely perfected his appeal. The deadline for filing Appellant's Brief with the Court is the 23rd day of March, 2015. Appellant's request for an extension is based upon the inability of the undersigned attorney to complete his

1 review of the record, which runs in excess of 1200 pages, and to finish research on the issues raised by the trial of the case.

II Said attorney would further show that he will require an additional thirty (30) days in which to complete the research and prepare Appellant's Brief on Appeal. This is Appellant's second request for an extension of time in which to file his brief.

Prayer WHEREFORE PREMISES CONSIDERED, Appellant prays this Honorable Court to grant his “Motion for Extension of Time to File Brief on Appeal,” and Order that the deadline for filing such be extended an additional thirty (30) days, until April 22, 2015, or until such time as set by this Court. Respectfully submitted,

____________________________________ David A. Schulman Attorney at Law Post Office Box 783 Austin, Texas 78767-0783 Tel. 512-474-4747 Fax: 512-532-6282 zdrdavida@davidschulman.com

State Bar Card No. 17833400

Attorney for Appellant

2 Certificate of Compliance and Delivery

This is to certify that: (1) this document, created using WordPerfect™

X7 software, contains 320 words, excluding those items permitted by Rule

9.4 (i)(1), Tex.R.App.Pro., and complies with Rules 9.4 (i)(2)(B) and 9.4 (i)(3),

Tex.R.App.Pro.; and (2) on March 23, 2015, a true and correct copy of the

above and foregoing motion for extension was transmitted via the eService

function on the State’s eFiling portal, to Laura E. Durbin

(laura.durbin@bexar.org), counsel of record for the State of Texas.

______________________________________ David A. Schulman