Ex Parte Hector Ramirez

Opinion

ACCEPTED

04-15-00125-CR

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

6/24/2015 8:29:12 AM

KEITH HOTTLE

CLERK

Nos. 04-15-00125-CR

STATE OF TEXAS § IN THE COURT OF APPEALS FILED IN

4th COURT OF APPEALS

VS. § SAN ANTONIO, FOURTH JUDICIAL TEXAS DISTRICT

6/24/2015 8:29:12 AM

HECTOR RAMIREZ GUTIERREZ § BEXAR COUNTY, KEITHTEXAS

E. HOTTLE Clerk

SECOND MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF

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From the 226 District Court of Bexar County, Texas Trial Court No. 2013-CR-2894-W1 Hon. Kevin O’Connell, Judge Presiding

In accordance with Tex. R. App. P. 10.5(b), the undersigned submits the following:

Appellant’s brief is due to be filed on Monday, the 29th of June, 2015. The undersigned

requests additional time to prepare and file Appellant’s opening brief. Counsel has been

working on several appellate cases pending in the Fourth Court of Appeals and the Third Court

of Appeals. Further, counsel has been preparing for various trial cases as well as assisting in one

trial case, State of Texas v. Derrick Diab, Cause No. 2014CR1195. Further, counsel is scheduled

to be out of town from June 24, 2015 through June 27, 2015. As a result, Counsel requests more

time to work on Appellant’s brief. Counsel requests an extension of twenty-one (21) days, to and

including Monday, July 20, 2015. This is Appellant’s second request for an extension.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this

Court grant the requested extension.

Respectfully submitted,

Robert A. Jimenez De Mott, McChesney, Curtright & Armendariz, LLC. 800 Dolorosa Street, Suite 100 San Antonio, Texas 78207 210/354-1844 210/212-2116 - fax

By: /s/ Robert A. Jimenez SBN: 24059125

CERTIFICATE OF SERVICE

I hereby certify that on this the 24th day of June, 2015 a copy of the foregoing “Motion

for Extension of Time to File Appellant’s Opening Brief” has been electronically filed with this

Court, and will be served to the Bexar County District Attorney’s Office on June 24, 2015.

/s/ ROBERT A. JIMENEZ