Case Information
*1 PD-0036-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS Transmitted 1/8/2015 9:28:08 AM Accepted 1/15/2015 4:22:41 PM ABEL ACOSTA MARISOL CARVAJAL-GARCIA CLERK ATTORNEY AT LAW 1600 E. MAIN STREET, SUITE 227 ALICE, TEXAS 78332 361.668.4989 PHONE 361.664.1003 FACSIMILE January 8, 2015 Via E-FILE
Abel Acosta, Clerk of the Court
Court of Criminal Appeals
Supreme Court Building
201 West 14 th Street, Room 106
Austin, Texas 78701
Re: Cause No. _______; Enrique Gonzalez, Jr. vs. State of Texas
Dear Mr. Acosta:
In reference to the above-styled cause, enclosed herewith for filing please find Appellant’s First Unopposed Motion to Extend Time to File Petition for Discretionary Review.
Opposing counsel is being provided with a copy of the same by the method indicated below.
If you have any questions or concerns, please do not hesitate to contact me.
Sincerely, MCG/jac
Enclosure
xc: Enrique Gonzalez, Jr.
Office of the District Attorney Via EMAIL
229 Judicial District
NO. ______________ ENRIQUE GONZALEZ, JR. § IN THE COURT OF
§ VS. § CRIMINAL APPEALS
§
STATE OF TEXAS § OF TEXAS
FIRST UNOPPOSED MOTION TO EXTEND TIME TO FILE PETITION FOR DISCRETIONARY REVIEW TO THE HONORABLE JUDGES OF SAID COURT:
Now comes Enrique Gonzalez, Jr., Appellant in the above styled and numbered cause, and moves for an extension of time of 30 days to file a petition for discretionary review, and for good cause shows the following:
1. On December 10, 2014, the Court of Appeals affirmed appellant's conviction. Enrique Gonzalez, Jr. v. State, Appellate Cause No. 04-13-00708-CR. This petition is therefore due on January 9, 2015.
2. Counsel has been unable to complete the petition for the following reasons: Trial Counsel's law partner was elected Jim Wells County Court at Law Judge and commenced work on January 1, 2015. Thus trial counsel has acquired a substantial case load. This Motion is not sought for delay but that justice may be done.
3. The undersigned conferred with Rumaldo Solis, Jr., Assistant District Attorney for the 229 Judicial District, who indicated there was no opposition to this *3 request.
4. Defendant is currently incarcerated.
WHEREFORE, PREMISES CONSIDERED , appellant respectfully requests an extension of 30 days, i.e. until February 10, 2015, to file a petition for discretionary review.
Respectfully submitted, Marisol Carvajal-Garcia Attorney at Law 1600 E. Main St., Suite 227 Alice, Texas 78332 Tel: 361.668.4989 Fax: 361.664.1003 By: /s/ Marisol Carvajal-Garcia Marisol Carvajal-Garcia State Bar No. 24065014 marisolcarvajal@hotmail.com Attorney for Enrique Gonzalez, Jr.
CERTIFICATE OF SERVICE This is to certify that on January 8, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Duval County, P.O. Drawer 1061, San Diego, Texas 78384, by E-mail.