Hector Ramirez v. State

Opinion

ACCEPTED

04-15-00124-CR

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS 10/13/2015 9:56:02 AM

KEITH HOTTLE

CLERK

Nos. 04-15-00124-CR

STATE OF TEXAS § IN THE COURT OF APPEALS FILED IN

4th COURT OF APPEALS

VS. § SAN ANTONIO, FOURTH JUDICIAL TEXAS DISTRICT

10/13/15 9:56:02 AM

HECTOR RAMIREZ GUTIERREZ § BEXAR COUNTY, KEITHTEXAS

E. HOTTLE Clerk

MOTION FOR EXTENSION OF TIME TO FILE MOTION TO DISMISS APPEAL From the 226th District Court of Bexar County, Texas Trial Court No. 2013-CR-2894-W1 Hon. Kevin O’Connell, Judge Presiding

In accordance with Tex. R. App. P. 10.5(b), the undersigned submits the following:

Appellant’s signed motion to dismiss was due to be filed on Wednesday September 30,

2015. After receiving notification from this Court that Appellant did not need to have his motion

to dismiss notarized, counsel notified Appellant’s wife, who had been facilitating contact between

Appellant, who is in Mexico, and counsel. Since that time, counsel had been unable to contact

Appellant or his wife, through either telephone or email. However, Counsel was able to contact

Appellant’s wife this afternoon. She advised counsel that Appellant had mailed out the documents

two to three weeks ago. Counsel is still hopeful he will receive the documents soon.

Counsel for Appellant respectfully requests, that he be granted an extension of fifteen (15)

days to try to secure the required documents from Appellant.

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 12th day of October, 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 October 12, 2015.

/s/ ROBERT A. JIMENEZ