Francisco Javier Gonzalez v. State

Opinion

ACCEPTED 04-14-00709-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 4/2/2015 10:38:51 AM KEITH HOTTLE CLERK

Nos. 04-14-00709-CR

STATE OF TEXAS § IN THE COURT OF APPEALS FILED IN 4th COURT OF APPEALS VS. § SAN ANTONIO, FOURTH JUDICIAL TEXAS DISTRICT 4/2/2015 10:38:51 AM FRANCISCO JAVIER GONZALEZ § BEXAR COUNTY, KEITHTEXAS E. HOTTLE Clerk MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF

From the 399th District Court of Bexar County, Texas Trial Court No. 2011-CR-9697 Hon. Ray J. Olivarri, 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 6th of April, 2015. The undersigned

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

received the trial court’s findings of fact and conclusions of law, tendered to counsel on March

31, 2015. Counsel has been working on Appellant’s brief but needs time to incorporate the

court’s ruling and amend his arguments. Counsel has also been preparing two writs of habeas

corpus, one in Bexar County and one in Dallas County, which have forced counsel to divert his

attention from this appeal. Counsel requests an extension of twenty-one (21) days, to and

including Monday, April 27, 2015. This is Appellant’s third request for an extension.

Appellant has spoken with the Bexar County District Attorney’s Office regarding

this motion and, per Chief Appellate Prosecutor RicoValdez, they are not opposed to

granting this request for an extension of time.

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 April, 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 April 2, 2015.

/s/ ROBERT A. JIMENEZ