Gonzalez, Enrique Jr.

• Court: Court of Appeals of Texas
• Decided: January 15, 2015
• Docket: PD-0036-15
• Status: Published

Opinion

PD-0036-15 COURT OF CRIMINAL APPEALS PD-0036-15 AUSTIN, TEXAS Transmitted 1/8/2015 9:28:08 AM Accepted 1/15/2015 4:22:41 PM MARISOL CARVAJAL-GARCIA ABEL ACOSTA CLERK ATTORNEY AT LAW 1600 E. MAIN STREET, SUITE 227 ALICE, TEXAS 78332 361.668.4989 PHONE 361.664.1003 FACSIMILE

January 8, 2015

Via E-FILE JANUARY 15, 2015 Abel Acosta, Clerk of the Court Court of Criminal Appeals Supreme Court Building 201 West 14th Street, Room 106 Austin, Texas 78701

Re: Cause No. _______; Enrique Gonzalez, Jr. vs. State of Texas

Dear Mr. Acosta:

In reference to the above-styled cause, enclosed herewith for filing please find Appellant’s First Unopposed Motion to Extend Time to File Petition for Discretionary Review.

Opposing counsel is being provided with a copy of the same by the method indicated below.

If you have any questions or concerns, please do not hesitate to contact me.

Sincerely,

/s/ Marisol Carvajal-Garcia

Marisol Carvajal-Garcia

MCG/jac Enclosure xc: Enrique Gonzalez, Jr.

Office of the District Attorney Via EMAIL 229th Judicial District NO. ______________

ENRIQUE GONZALEZ, JR. § IN THE COURT OF § VS. § CRIMINAL APPEALS § STATE OF TEXAS § OF TEXAS

FIRST UNOPPOSED MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW

TO THE HONORABLE JUDGES OF SAID COURT:

Now comes Enrique Gonzalez, Jr., Appellant in the above styled and

numbered cause, and moves for an extension of time of 30 days to file a petition for

discretionary review, and for good cause shows the following:

1. On December 10, 2014, the Court of Appeals affirmed appellant's

conviction. Enrique Gonzalez, Jr. v. State, Appellate Cause No. 04-13-00708-CR.

This petition is therefore due on January 9, 2015.

2. Counsel has been unable to complete the petition for the following

reasons: Trial Counsel's law partner was elected Jim Wells County Court at Law

Judge and commenced work on January 1, 2015. Thus trial counsel has acquired a

substantial case load. This Motion is not sought for delay but that justice may be

done.

3. The undersigned conferred with Rumaldo Solis, Jr., Assistant District

Attorney for the 229th Judicial District, who indicated there was no opposition to this request.

4. Defendant is currently incarcerated.

WHEREFORE, PREMISES CONSIDERED, appellant respectfully

requests an extension of 30 days, i.e. until February 10, 2015, to file a petition for

discretionary review.

Respectfully submitted,

Marisol Carvajal-Garcia Attorney at Law 1600 E. Main St., Suite 227 Alice, Texas 78332 Tel: 361.668.4989 Fax: 361.664.1003

By: /s/ Marisol Carvajal-Garcia Marisol Carvajal-Garcia State Bar No. 24065014 marisolcarvajal@hotmail.com Attorney for Enrique Gonzalez, Jr.

CERTIFICATE OF SERVICE

This is to certify that on January 8, 2015, a true and correct copy of the above

and foregoing document was served on the District Attorney's Office, Duval

County, P.O. Drawer 1061, San Diego, Texas 78384, by E-mail.

/s/ Marisol Carvajal-Garcia Marisol Carvajal-Garcia