Jorge Zepeda v. State

• Court: Court of Appeals of Texas
• Decided: May 8, 2015
• Docket: 12-15-00055-CR
• Status: Published

Opinion

ACCEPTED 12-15-00055-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 5/8/2015 3:45:45 PM CATHY LUSK CLERK

Cause No. 12-15-00055-cR JORGE ZEPEDA $ IN THE COI]RT OF APPEALS $ FILED IN V. $ 12TH DISTRICT12th COURT OF APPEALS COURT TYLER, TEXAS $ STATE OF TEXAS TYLER, TEXAS5/8/2015 3:45:45 PM CATHY S. LUSK Clerk

TO THE HONORABLE JUDGES OF SAID COURT:

COMES NOW, Appellant, through JEFF SANDERS, Defense Attorney, in the above

show the Court as styled and numbered cause and files this Motion and in support thereof would

follows:

1. The Appellant's Brief is due on May 11,2015. Appellant's attorney needs 30

additional days to file the brief. This is the first request for an extension.

2. I have been involved in trial preparation for State v. Kaylee Harrod, cause numbers

CR14-28 1 and CRl 4- 323 , in Rusk County District Court set for Ap/rl 27 , 2015

(delivery of a controlled substance and endangering a child). Additionally' I've been

working on trial preparation for State v. John Mumphrey, cause number 43486-A, in

Gregg County District Court that had been set for trial April 20, 2015 (felony DWD.

Furthermore, I have been involved in case preparation on State v. Jacob Roper, cause

number t14-0320-15 & 114-0321-15 &,114-0322-l5,in smith county (two counts

ofaggravated robbery and burglary ofa building)'

3. This motion is not made for purposes of delay, but so that justice may be done.

granted. WHEREFORE, PREMISES CONSIDERED, the Appellant requests that this motion for be Re specJf-ully S ubmiued

State Bar Number 24033153 ELLIS ANd SANDERS PLLC 120 S. Broadway Suite 112 Tyler, Texas 75702 Pirone (903)595-1 13 1 Fax (903)595-5532

CEhRTIFICATE OF SERVICE attorney This is to certiff that a true and correct copy of the foregoing Motion was served upon the for the State on 8TH of May,2A15.

VERIFICATION

STATE OF TEXAS $ $ KNOW ALL MEN BY THESE PRESENTS COUNTY OF SMITH $

.,My name is JEFF SANDERS and I am the attorney for the Appellant in this case. I have

knowledge of the facts stated in the foregoing Motion and they are true and correct."

Signed on 0rta.1 8 ,2a15.

SWORN AND SUBSCRIBED TO BEFORE ME, the undersigned Notary Public on

Glnot Atffi HoYtril fy Commtrrhn Erghrg April 26, 2016 Notary Public in and for the State of