Joaquin Alberto Davila v. State

• Court: Court of Appeals of Texas
• Decided: January 5, 2015
• Docket: 04-14-00592-CR
• Status: Published

Opinion

ACCEPTED 04-14-00592-cr FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 1/3/2015 9:27:25 PM KEITH HOTTLE CLERK

NO. 04-14-00592-CR ________________________________________________________________________ FILED IN 4th COURT OF APPEALS IN THE FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS SAN ANTONIO, TEXAS 1/5/2015 9:16:00 AM KEITH E. HOTTLE Clerk JOAQUIN ALBERTO DAVILA

Appellant

v.

THE STATE OF TEXAS,

Appellee ___________________________________________________________________

On Appeal from County Court No. 2, Webb County, Texas Honorable Jesus Garza, Presiding Judge Trial Court Cause No. 2013-CRB377-L2 ________________________________________________________________________

MOTION FOR EXTENSION OF TIME TO FILE BRIEF

___________________________________________________________________

TO THE HONORABLE COURT OF APPEALS:

Appellant, Joaquin Alberto Davila, by and through his undersigned attorney,

hereby moves the Court for an Order extending the time to file Appellant’s Brief,

and as grounds therefor would show the Court the following:

1. Appellant’s Brief is due on or before January 3, 2015.

2. Appellant respectfully requests that the Court extend his current briefing

deadline of January 3, 2015, to and including January 10, 2015. There has been one extension of time granted for the filing of Appellant’s Brief.

3. Appellant requests an extension to January 10, 2015 for the filing of the brief

because undersigned counsel has been involved in a number of other legal

proceedings and matters that have required or will require a substantial amount of

his time. In addition, counsel has been ill for the past week and it has hindered all

work and will prevent him from completing the Appellant’s Brief before January 3,

2015. Given that, undersigned counsel has not had, and will not have, an

opportunity to properly prepare the brief on the issues in this matter by the current

deadline.

4. Absent any more extraordinary circumstances, Appellant will not file any

further motions for extension of time to file Appellant’s Brief.

WHEREFORE, Appellant prays that the time for filing his brief be extended

to and including January 10, 2015; and for such other and further relief as the Court

may deem to be just and proper.

Respectfully submitted,

/s/Omar Salinas Omar Salinas Assistant Public Defender Webb County Public Defender’s Office 1110 Washington Laredo, Texas 78040 Tel: (956) 523-4119 Fax: (956) 523-5009 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was hand-

delivered, faxed, or forwarded through the Court’s electronic case filing system to

the Webb County District Attorney’s Office 1110 Victoria Street, Suite 401,

Laredo, Texas 78040, on January 3, 2015.

/s/Omar Salinas Omar Salinas Assistant Public Defender Webb County Public Defender’s Office 1110 Washington Laredo, Texas 78040 Tel: (956) 523-4119 Fax: (956) 523-5009