Sergio Delgado Dominguez v. State

Opinion

ACCEPTED 03-14-00086-CR 4461115 THIRD COURT OF APPEALS AUSTIN, TEXAS 3/11/2015 3:14:49 PM JEFFREY D. KYLE CLERK CAUSE NO. 03-14-00086-CR

FILED IN 3rd COURT OF APPEALS EX PARTE: § AUSTIN,COURT IN THE APPEALS TEXAS 3/11/2015 3:14:49 PM § JEFFREY D. KYLE SERGIO DELGADO DOMINGUEZ § THIRD DISTRICT OF ClerkTEXAS APPLICANT §

APPLICANTS’ MOTION TO EXTEND TIME TO FILE BRIEF

NOW COMES, Petitioner, SERGIO DELGADO DOMINGUEZ, through

his attorney of record, JUAN R. GONZALEZ, respectfully requests this Honorable

Court to extend the time to file Petitioner’s Brief in Support of the Notice of Appeal,

Appellant’s Brief. Petitioner requests the extension in the interest of justice and

not for delay.

1. Petitioner is the person named as the defendant in the above-entitled action,

2. Petitioner’s attorney was present in two Master Calendar Hearings and one

Bond Hearing in Immigration Court in San Antonio, Texas on March 9, 2015.

3. Petitioner’s attorney is transiting into a new office location, and due to

unforeseen circumstances has been unable to connect to the internet access.

For the reasons stated above, Petitioner requests this Honorable Court to

extend the time to file Petitioner’s brief an additional thirty (30) days to April 9,

2015.

Dated: March 10, 2015. Respectfully Submitted,

___/S/Juan R. Gonzalez_____ Juan R. Gonzalez Juan R. Gonzalez, PLLC 8023 Vantage Drive, Suite 400 San Antonio, Texas 78230 O: (210) 591-8878 F: (210) 579-1011 jrgonzalez@jrgonzalezlawfirm .com CERTIFICATE OF SERVICE

I, JUAN R. GONZALEZ, hereby certify that a true and correct copy of Motion to Extend Time to File Brief has been forwarded by facsimile on this, the 11 day of March, 2015 to:

Georgette Hogarth Assistant District Attorney State Bar No. 24007129 P.O. Box 1748 Austin, Texas 78767 (512) 854-9400 Fax No. 854-4206

___/S/Juan R. Gonzalez_____ JUAN R. GONZALEZ