Vasquez, Elias Esequiel

• Court: Court of Appeals of Texas
• Decided: March 2, 2015
• Docket: PD-0235-15
• Status: Published

Opinion

PD-0235&0236 COURT OF CRIMINAL APPEALS PD-0235-15 & PD-0236-15 AUSTIN, TEXAS Transmitted 2/27/2015 5:41:45 PM Accepted 3/2/2015 11:48:22 AM ABEL ACOSTA NO. PD-__________ AND PD-____________ CLERK

IN THE COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS

ELIAS ESEQUIEL VASQUEZ, Appellant

vs.

THE STATE OF TEXAS, Appellee

APPELLANT VASQUEZ’S MOTION FOR EXTENSION OF TIME TO FILE PDR IN APPELLATE CAUSE NOS. 04-13-00338-CR AND 04-13-00339-CR

Respectfully submitted by Appellant's attorney,

VICTORIA GUERRA Texas Bar No. 08578900 3219 N. McColl Rd. McAllen, Texas 78501 (956) 618-2609 (956) 618-2553 Fax

March 2, 2015 MAY IT PLEASE THE COURT:

COMES NOW Elias Esequiel Vasquez, Appellant in the above styled

cause, and files this motion for extension of time to file his PDRs, and

would show this Court the following:

At 2:00 a.m. on February 18, 2015, the Undersigned filed an

appellant’s brief in the Thirteenth Court of Appeals in the case of State v.

Chakravarthy, Cause No. 13-14-00086-CR. Its record consisted of over

8,000 pages and the brief contained over 9 issues, plus sub-parts. At 4:00

a.m., the Undersigned had to go to Austin to attend a mandatory training

for Independent Hearing Examiners for the Texas Education Agency. The

Undersigned stayed in Austin the rest of that week taking care of sundry

business matters. The Undersigned returned from Austin on February 22,

2015. Up to today, the Undersigned has been catching up with her many

other cases that were put on the back burner until the aforementioned brief

was filed. As such, Appellant seeks an extension of time to file this PDR to

this day, February 27, 2015.

WHEREFORE, Appellant prays that this Court grant his motion for

extension of time to file his PDRs. Respectfully submitted,

Law Office of Victoria Guerra 3219 N. McColl Rd. McAllen, Texas 78501 (956) 618-2609 (956) 618-2553 (facsimile)

By: /s/ Victoria Guerra Victoria Guerra State Bar Number: 0857900 Appellate Attorney for Appellant

CERTIFICATE OF SERVICE

On this 27th day February, 2015, the undersigned delivered a copy of

the foregoing Appellant’s motion for extension of time to file Appellant’s

brief to Appellee’s Counsel jaolson_ccda@yahoo.com or his facsimile: 210-

858-6780 and to the State Prosecuting Attorney at its fax: (512) 463-5724.

/s/ Victoria Guerra Victoria Guerra, Attorney for Appellant

CERTIFICATION OF COMPLIANCE

In compliance with TRAP 9.4(i)(3), the undersigned certifies that the

number of words in this brief, excluding those matters listed in Rule 9.4(i)

(l), is 191.

/s/ Victoria Guerra Victoria Guerra