State v. Reyes, Ex Parte Juan Carlos
This text of State v. Reyes, Ex Parte Juan Carlos (State v. Reyes, Ex Parte Juan Carlos) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
PD-1277-14 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 12/26/2014 3:34:29 PM Accepted 12/29/2014 7:57:40 AM ABEL ACOSTA COURT OF CRIMINAL APPEALS OF TEXAS CLERK AUSTIN, TEXAS
NO. PD-1277-14 December 29, 2014 APPEAL COURT NO. 08-12-00261-CR TRIAL COURT NO. 20050C17647-CC7-1
THE STATE OF TEXAS, * Respondent, * * VS. * * JUAN CARLOS REYES * Petitioner. *
MOTION FOR AN EXTENSION OF TIME TO FILE PETITIONER’S BRIEF ON THE MERITS
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
COMES NOW, the Petitioner, Juan Carlos Reyes, and files this first motion for
an extension of time to file Petitioner’s Brief on the Merits. Petitioner would show
the Court the following:
(a) Undersigned counsel believed that he had a period of time after the due date of December 19, 2014 to file his first motion for an extension of time to file his brief. Because of his heavy workload and through oversight, undersigned counsel did not realize that he needed to file his first motions to extend time to file brief on or before the due date of the brief. Accordingly, undersigned counsel, through mistake and oversight, did not realize that he was late in filing this first motion to extend time to file his brief with this Court.
Page -1 (b) Complicating matters is the heavy workload that undersigned counsel had over the previous month. One of the projects he was working on a Petition for Writ of Certiorari which was filed with the United States Supreme Court on December 18, 2014 in a case styled Luis Salazar v. William Sanders and Patricia Sanders. The preparation of this petition took considerable time.
(b) The Petitioner’s brief petition for discretionary review was due on December 19, 2014.
(c) This is the Petitioner’s first request for extension of time.
(d) This extension is requested for five (7) days, until December 26, 2014.
PRAYER
WHEREFORE, Petitioner prays that his extension request will be granted until
December 26, 2014
Respectfully submitted,
/s/ James D. Lucas JAMES D. LUCAS Attorney for Petitioner 2316 Montana Avenue El Paso, Texas 79903 Tel: (915) 532-8811 Fax: (915) 532-8807 SBN 12658300 jlucas2@elp.rr.com
Page -2 CERTIFICATE OF SERVICE
I, James D. Lucas, hereby certify that on the 26th of December , 2014, a true and
correct amended copy of the foregoing instrument was delivered to the below-named
individuals by electronic means:
Lily M . Strout Asst. District Attorney El Paso County Courthouse 500 E. San Antonio, Room 201 El Paso, Texas 79901 tdarnold@ e[county.com
State Prosecuting Attorney P.O. Box 12405 Austin, Texas 78711 inform ation@ spa.texas.gov
Dated this 26th day of December, 2014.
/s/ Jam es D . Lucas JAM ES D. LUCAS
Page -3
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