John Gabriel Esquivel v. State

Opinion

ACCEPTED 03-15-00439-CR 7697655 THIRD COURT OF APPEALS AUSTIN, TEXAS 11/5/2015 11:20:01 AM JEFFREY D. KYLE CLERK CAUSE NO. 03-15-00439-CR

JOHN GABRIEL ESQUIVEL § IN THE THIRD COURT Appellant, § FILED IN 3rd COURT OF APPEALS § AUSTIN, TEXAS § 11/5/2015 11:20:01 AM V. § OF APPEALS JEFFREY D. KYLE § Clerk THE STATE OF TEXAS § Appellee, § STATE OF TEXAS

FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES JOHN ESQUIVEL, Appellant, by and through their attorney, Amber

Vazquez Bode, and file this First Motion for Extension of Time to File Appellant's Brief. In

support thereof Appellant offers as follows:

1. According to the Texas Rules of Appellate Procedure Rule 38.6 Time to File

Briefs:

"(a) Appellant's Filing Date. Except in a habeas corpus or bail appeal, which is

governed by Rule 31, an appellant must file a brief within 30 days-20 days in an accelerated

appeal-after the later of:

(1) The date the clerk's record was filed; or

(2) The date the reporter's record was filed."

2. The Reporter's Record was filed on October 8, 2015.

3. The appellant's brief is due on November 9, 2015.

4. The Appellant cites the following facts and reasons to the Court as Justification

for this Motion for Extension: a) Counsel is preparing for a Trial in the 450th District Court in Travis County

Texas; Cause No. D-1-DC-14-206730.

5. Appellant hereby requests an extension of 30 days due to the stated reasons.

6. Appellant respectfully requests a brief extension of 30 days in order to receive

proper research for the case.

The Appellant respectfully requests that this court GRANT the First Motion for

Extension of Time to File Appellant's Brief.

Amber Vazquez Bode ______... State Bar No. 24039225 The Vazquez Law Firm 1004 West Ave. Austin, Texas 78701 (512) 220-8507 (telephone) (512) 480-0760 (facsimile)

COUNSEL FOR APPELLANT CERTIFICATE OF SERVICE

I, AMBER VAZQUEZ BODE, Attorney for Appellant, do hereby certify that a true and

correct copy of the above and foregoing First Motion for Extension of Time to File

Appellant's Brief has been served electronically on November 5, 2015. /) I /·-, I

'' i ~ / ;' -~ .{; i;, \ /' ( ·--~,: :,J~~-~ AMBER VAZQUEZ BODE Attorney for AppeHanr

Third Court of Appeals Price Daniel Sr. Bldg. 209 West 14th Street, Room 101 Austin, Texas 78701

Ms. Angela Chambers 299th District Court Official Court Reporter

299th Judicial District Court Blackwell-Thurman Justice Center 509 West 11th Street- 8th Floor Austin, Texas 78701

Travis County District Attorney Appellate Division 509 West 11th Street Austin, Texas 78701

Travis Count~ District Clerk 509 West 11 t Street, Room 1.400 Austin, Texas 78701

The Honorable Karen Sage 299th District Court Blackwell-Thurman Justice Center 509 West 11th Street- 8111 Floor Austin, Texas 78701