Joseph Baruch Rodriguez v. State

Opinion

ACCEPTED 14-15-00243-CR FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 8/31/2015 7:36:28 AM CHRISTOPHER PRINE CLERK

NO. 14-15-00243-CR

IN THE COURT OF APPEALS FILED IN FOR THE 14th COURT OF APPEALS HOUSTON, TEXAS FOURTEENTH SUPREME JUDICIAL DISTRICT OF TEXAS 8/31/2015 7:36:28 AM AT HOUSTON CHRISTOPHER A. PRINE _______________________________________________________Clerk

JOSEPH BARUCH RODRIGUEZ Appellant

v.

THE STATE OF TEXAS, Appellee _______________________________________________________

Appeal from Cause No. 12CR2802 In the 405th District Court of Galveston County, Texas __________________________________

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF FOR APPELLANT _________________________________

To the Honorable Justices of the Court of Appeals:

Appellant, JOSEPH BARUCH RODRIGUEZ, by and through his Counsel of

Record, JARED ROBINSON, files this Unopposed Motion to Extend Time to File Brief

and in support shows this Court the following:

I.

Appellant pled guilty to one count of Possession of a Controlled Substance, in the

amount of 1 to 4 grams on October 17, 2012. The court assessed punishment at 5 years

Deferred Adjudication Probation. On September 29th, 2014, the State of Texas filed a Motion to Adjudicate Guilt-

Revoke Community Supervision. A contested hearing was held on December 18th, 2014,

and the court found “true” that the defendant had violated conditions 1, 16A, 19, 22, and

26 of defendant’s probation. On February 13, 2015 the court sentenced appellant to

confinement in the Texas Department of Criminal Justice for a period of Six (6) years.

II.

Appellant’s brief is due on or before August 30, 2015. Appellant’s counsel

respectfully requests an extension for at least sixty days to file Appellant’s brief. The

Assistant District Attorney handling the case, Rebecca Klaren, has indicated the State of

Texas is unopposed to Appellant’s request for an extension.

Appellant’s counsel needs additional time to complete his brief and additional

time to review the Reporter’s Record because of conflicts created by work in other cases.

More specifically, counsel for Appellant has been diligently preparing for multiple trials

that were scheduled to begin in Galveston County on August 24th and preparing for

another trial scheduled to begin in Galveston County on September 14th. This is the first

request for an extension of time filed with this Court. Therefore Counsel requests that

this Court extend the time to file Appellant’s Brief until at least October 30th, 2015.

Respectfully Submitted,

JONES ROBINSON, LLP.

/s/ Jared S. Robinson /s/ JARED S. ROBINSON State Bar No.: 24060506 1100 Rosenberg Avenue Galveston, Texas 77550

2 409.765-5705 409.765.7570 Facsimile

ATTORNEY FOR APPELLANT

CERTIFICATE OF SERVICE

I hereby affirm a true and correct copy of the foregoing was delivered via hand-

delivery and/or electronic delivery to Rebecca Klaren, Assistant Galveston County

Criminal District Attorney, on the 29th day of August 2015.

/s/ Jared S. Robinson JARED S. ROBINSON

CERTIFICATE OF CONFERENCE

I hereby certify and affirm that I have communicated on the 29th day of August,

2015 with Rebecca Klaren, Assistant Galveston County Criminal District Attorney,

regarding Appellant’s request for an extension of time to file his brief and she has

indicated that the State of Texas is Unopposed to this request.

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