Moises Renteria v. State

Opinion

ACCEPTED

06-15-00106-CR

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

9/16/2015 7:18:39 PM

DEBBIE AUTREY

CLERK

No. 06-15-00106-CR

IN THE COURT OF APPEALS FILED IN 6th COURT OF APPEALS

TEXARKANA, TEXAS

FOR THE SIXTH APPELLATE DISTRICT 9/17/2015 8:12:00 AM

DEBBIE AUTREY

TEXARKANA, TEXAS Clerk

MOISES RENTERIA APPELLANT VS STATE OF TEXAS APPELLEE MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT

TO HONORABLE JUDGES OF SAID COURT:

NOW COMES, the Appellant by and through his Attorney, Tim Cone, and does hereby move this Honorable Court to grant an extension of time for the purpose of filing the Appellant’s Brief.

I.

Judgment was entered with the 188th District Court of Gregg County, Texas, in Cause Number 38,802-A styled The State of Texas vs. Moises Renteria, on the 1st day of August, 2011. An out of time appeal was granted by the Texas Court of Criminal Appeals on June 15, 2015. The Appellant’s brief is due on September 17, 2015. This is the Appellant’s first request for an extension of time for the late filing of Appellant’s brief.

Appellant’s attorney requests an extension of time for late filing of a brief until October 17th, 2015, and will, hopefully be the last request for extension of time for late filing of said brief and would show to the Court the following: Appellant’s attorney was on a prepaid vacation from August 21, 2015, through August 30, 2015. Unfortunately, upon returning from said vacation, Appellant’s attorney contracted pneumonia and was very ill for about 10 days. A great deal of work stacked up during the time of the vacation and ensuing illness. Further, Appellant’s attorney has recently submitted a brief to this Court in the case of Derek Clinton Ward, Case 06-15-00110-CR. Further, although it may be irrelevant, the extension in the case at bar is likely in relation to the last brief Appellant’s attorney will submit to this Court due to an impending retirement.

WHERWFORE, PREMISES CONSIDERED, Appellant’s attorney respectfully requests that this Honorable Court grant Appellant’s request for an Extension to file a late brief until October 17, 2015. . Respectfully Submitted, /s/Tim Cone

______________________________

Tim Cone, Attorney At Law State Bar N. 04660350

P.O. Box 413

Gilmer, Texas 75644

903-725-6270

e-mail: timcone6@aol.com

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing Appellant’s Motion for Extension of Time to File Brief has been served to Zan Brown, Assistant Criminal District Attorney for Gregg County, attorney for Appellee, on this the 16th day of September, 2015.

/s/Tim Cone

_____________________________

Tim Cone, Attorney At Law