Case Information
*-668 The clerk’s record was filed on October I6, 2014. The State filed its brief on
*-667 Certificate of Compliance and Service *-666 Respectfully submitted, *-636 hereby certify that this brief contains 485 words, based upon the computer *-608 (b) The Appellee’s brief is currently due on *-606 program used to generate this brief and excluding words contained in those parts of *-582 K *-577 (c) This request is that the deadline for filing the Appellee’s brief be *-576 brief that Texas Rule of Appellate Procedure 9.4(i) exempts from inclusion in *-561 Ramirez *-547 extended by 30 days. *-546 word count, and that this brief is printed in a conventional, I4-point typeface. SBN: *-530 I603 Babcock, Suite I59 *-517 further certify that, on the 26"‘ day of January, 2015, a true and correct (d) The number of previous extensions of time granted for submission of *-515 San Antonio, Texas *-500 (210) 785-0443
*-487 Appellee’s brief is: none. *-485 Fax: (210) 785-0453 copy of this brief was served, by U.S. mail, electronic mail, facsimile, or *-470 Email: rocio@rocioramirezlaw.com *-456 (e) The Appellee relies upon the following facts to reasonably explain *-454 electronically through the electronic filing manager, to the Appel|ant’s attorneys, *-426 need for an extension of deadline: *-425 Angie Creasy, Assistant District Attorney, P.O. Box 1748, Austin, Texas 78767, *-396 l.
The undersigned counsel is a sole practitioner. The undersigned counsel *-395 fax: (512) 854-48 I 0, email:Angie.Creasy@traviscountytx.gov. *-366 has been preparing for a trial which is currently set for February 3, 2015, The State *-336 of Texas v. Benjamin Anguiarzo-Hernandez, Cause No. 431776 and has numerous *-318 Ramirez *-305 pre-trial hearings and immigration matters through January *-275 In addition, this case involves complex issues of fact and law. Counsel *-245 must conduct extensive legal research in order to prepare the Appellee’s brief. *-215 This request is not made for the purpose of delay, but to ensure that *-185 Court has a proper Appellee’s brief to aid in thejust disposition of the above cause.
*-155 WHEREFORE, the Appellee respectfully requests that the deadline for *-124 filing the Appellee’s brief be extended to February 26, 2015. *0 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 1/26/2015 5:02:43 PM JEFFREY D. KYLE Clerk
*1 ACCEPTED 03-14-00602-CR [3905371] THIRD COURT OF APPEALS AUSTIN, TEXAS 1/26/2015 5:02:43 PM JEFFREY D. KYLE CLERK No. 03-14-00602-CR In the Court of Appeals Third District Austin, Texas
The State of Texas, Appellant V. Anthony James Sanchez, Appellee Appeal from the l67th Judicial District Court Travis County, Texas Cause Number D- l -DC-I 3-200502 APPELLEE’S FIRST MOTION FOR EXTENSION OF TIME TO THE HONORABLE COURT OF APPEALS: The Appellee, Anthony James Sanchez, by and through the undersigned counsel Rocio Ramirez, moves for an extension of the deadline for filing the State’s brief and, in accordance with Texas Rules of Appellate Procedure 38.6 and l0.5(b), advises the Court as follows:
(a) The appellee filed a Motion to Suppress Evidence on January 27, 2014. The Trial Court filed an Order granting the Motion to Suppress Evidence on August 29, 2014. The State of Texas filed a notice of Appeal in the above cause on September I8, 2014. The reporter’s record was filed on September 30, 2014. [1]