Case Information

*0 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 08/05/15 4:28:45 PM KEITH E. HOTTLE Clerk *1 ACCEPTED 04-14-00670-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 8/5/2015 4:28:45 PM 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

UNOPPOSED MOTION FOR EXTENSION OF TIME

TO FILE REPLY 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 for Extension of Time to File Reply Brief,” and shows as follows:

This Court’s current briefing deadline is Thursday, August 6 th , 2015. Since the filing of

the State’s response brief, the undersigned has filed the following:

On Friday, July 31, 2015, Counsel filed a reply brief with this Court in State v. Luis

Arnaldo Baez , Cause No. 04-14-00374-CR;

On Wednesday, July 22, 2015, Counsel filed a petition for discretionary review (Cause

No. PD-0756-15), with the Texas Court of Criminal Appeals, stemming from the San Antonio,

Fourth Court of Appeals decision in Arrington v. State , 2015 Tex. App. LEXIS 2529 (Tex. App.

San Antonio Mar. 18, 2015), involving four 60 and one 20 year (concurrent) sentences for sexual

assault-related convictions;

Counsel has pretrial motions due to be filed no later than August 10 , 2015, in State v.

Shawn Dillard , Cause No. 2015-CR-5293A, pending in the 290 D. Ct. of Bexar County, Texas,

a capital murder prosecution in which the State (at least currently), has announced that they will

seek the death penalty.

Counsel has prepared for a hearing, which is scheduled before the Hon. Pamela Mathy,

on Thursday, August 6 , 2015 @ 9:30 a.m, in United States v. Shepherd , Cause No. SA:12-CR-

643-XR, involving a 28 U.S.C. § 2255 petition.

On Tuesday, August 4 , 2015, the undersigned counsel consulted with Ms. Mary

Beth Welsh, Asst. Dist. Atty. with the Appellate Division of the Bexar County District

Attorneys Office, who informed that she had no opposition to the requested extension of

time.

WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this

Court grant the requested 12-day extension of time to file his reply brief, to and including

Monday, August 17, 2015.

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 5 of August, 2015 a copy of the foregoing “Unopposed

Motion for Extension of Time to file Reply Brief” has been delivered to the Appellate Section of

the Bexar County District Attorney’s Office, via email.