Francisco Javier Gonzalez v. State

Opinion

ACCEPTED 04-14-00709-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 3/11/2015 8:10:00 PM 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 3/11/2015 8:10:00 PM 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 16th of March, 2015. The undersigned

requests additional time to prepare and file Appellant’s opening brief. Counsel is still waiting

on the trial court to submit written findings of fact and conclusions of law. Counsel was

informed last week that these findings are being prepared and should be completed soon.

Findings of fact and conclusions of law would assist all parties in this appeal and Counsel would

request additional time to allow the trial court to enter its findings. Counsel has already been

working on Appellant’s brief to insure that it is prepared as expeditiously as possible. Counsel

requests an extension of twenty-one (21) days, to and including Monday, April 6, 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 11th day of March, 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 March 12, 2015.

/s/ ROBERT A. JIMENEZ