Case Information
*0 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 2/2/2015 9:36:48 AM KEITH E. HOTTLE Clerk *1 ACCEPTED 04-14-00670-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 2/2/2015 9:36:48 AM KEITH HOTTLE CLERK
No. 04-14-670-CR
STATE OF TEXAS § IN THE COURT OF APPEALS
VS. § FOURTH JUDICIAL DISTRICT
SIMON RENE GARCIA § BEXAR COUNTY, TEXAS
SECOND, UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE OPENING BRIEF
From the 175 th District Court of Bexar County, Texas
Trial Court No. 2012-CR-10101
Hon. Mary Roman, Judge Presiding
In accordance with Tex. R. App. Pro. 10.5(b)(1), the undersigned counsel submits his
“Unopposed Motion to for Extension of Time to File Opening Brief,” and shows as follows:
This Court’s current briefing deadline is Monday, February 2, 2014. Counsel needs
additional time to finish all legal research related to the brief, and will need an additional 30-day
extension of time to complete it. Counsel underwent shoulder surgery on Tuesday, November
25, 2014, which prevented him full use of his left arm, and the ability to type, for approximately
three weeks. Additionally, the undersigned is currently finishing his brief in State v. Baez ,
Cause No. 04-14-00374-CR, for which he has asked a third extension.
On Wednesday, December 30, the undersigned counsel consulted with Mr. Rico
Valdez, Assistant District Attorney with the Bexar County District Attorney’s Appellate
Section, who expressed no opposition to the requested extension of time.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this
Court grant the requested extension of time to file his opening brief.
Respectfully submitted,
Jorge G. Aristotelidis
Tower Life Building
310 South St. Mary’s Street, Suite 1830
San Antonio, Texas 78205
210/277-1906
jgaristo67@gmail.com
By:
SBN: 00783557
CERTIFICATE OF SERVICE
I hereby certify that on this the 2 nd day of February, 2015 a copy of the foregoing
“Second, Unopposed Motion for Extension of Time to file Opening Brief” has been delivered to
the Appellate Section of the Bexar County District Attorney’s Office, via email.