Geneva Doris Vasquez v. State

Opinion

ACCEPTED

12-14-00283-CR

TWELFTH COURT OF APPEALS

TYLER, TEXAS

3/6/2015 2:16:57 PM

CATHY LUSK

CLERK

NO. 12-14-00283-CR

ON APPEAL FROM THE 159TH JUDICIAL DISTRICT COURTFILED IN ANGELINA COUNTY, TEXAS 12th COURT OF APPEALS TYLER, TEXAS

CAUSE NO. 2014-0421 3/6/2015 2:16:57 PM CATHY S. LUSK

TH Clerk

GENEVA DORIS VASQUEZ § IN THE 12 COURT OF APPEALS § § OF

vs. § §

STATE OF TEXAS § TYLER, TEXAS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:

Now comes Geneva Doris Vasquez, Appellant in the above styled and numbered cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following:

1. This case is on appeal from the 159th District Court of Angelina County, Texas.

2. The case below was styled the STATE OF TEXAS vs. Geneva Doris Vasquez, and numbered 2014-00421.

3. Appellant was convicted of Burglary of a Habitation. 4. Appellant was assessed a sentence of Fifteen (15) years Texas Department of Criminal Justice Institutional Division on August 29, 2014.

5. Notice of appeal was given on September 26, 2014. 6. The clerk's record was filed on October 27, 2014; the reporter's record was filed on January 5, 2015.

7. The appellate brief is presently due on March 6, 2015. 8. Appellant requests an extension of time of three (3) days from the present date.

9. One extension to file the brief has been received in this cause. 10. Defendant is currently incarcerated. 11. Appellant relies on the following facts as good cause for the requested extension:

The above captioned brief is complete excepting editing and proofing. Due to court schedules, Counsel will be unable to submit the brief by end of business and therefore requests three days extension.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this Motion to Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate.

Respectfully submitted:

/s/John D. Reeves

____________________

John D. Reeves Attorney at Law 1007 Grant Lufkin, Texas 75901 Phone (936) 632-160 Fax: (936) 632-1640 tessabellus@yahoo.com SBOT # 16723000 Counsel for Appellant

CERTIFICATE OF CONFERENCE

Pursuant to Tex. R. App. 10.1 (5), certify that the staff of the undersigned conferred with opposing counsel who indicated that she does not oppose this motion.

/s/John D. Reeves

___________________________

John D. Reeves

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Appellant’s First Motion to Extend Time to file Appellant’s Brief on this 6th day of March, 2014 forwarded to State’s Attorney, April Ayers-Perez, Assistant District Attorney, Angelina County, by electronic service at aperez@angelinacounty.net.

/s/John D. Reeves

__________________________

John D. Reeves Attorney for Appellant, Geneva Doris Vasquez