Francisco Javier Gonzalez v. State

Opinion

ACCEPTED 04-14-00709-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 4/23/2015 11:10:54 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 4/23/2015 11:10:54 AM FRANCISCO JAVIER GONZALEZ § BEXAR COUNTY, TEXAS KEITH E. HOTTLE Clerk FOURTH 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 27th of April, 2015. The undersigned

requests additional time to prepare and file Appellant’s opening brief. Counsel is set for jury

trial on Monday, April 27th, in Williamson County, in Cause Number 14-04880-3, State of Texas

vs. Juan Vasquez Galarza. Counsel has been preparing for trial in the event the Court chooses to

proceed in this cause. As a result, Counsel has been unable to finish Appellant’s brief. While this

is counsel’s fourth request for an extension, the previous requests were due mostly to awaiting

the trial court’s written findings of fact. Counsel requests an extension of seven (7) days, to and

including Monday, May 4, 2015. This is Appellant’s fourth request for an extension.

Counsel has spoken with Ms. Laura Durbin, attorney with the Bexar County District

Attorney’s Office Appellate Section, and she has indicated that she is NOT OPPOSED to

Appellant’s request.

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 23rd 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 23, 2015.

/s/ ROBERT A. JIMENEZ