Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/10/2015 1:16:05 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED No. 01-14-00982-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 4/10/2015 1:16:05 PM CHRISTOPHER PRINE CLERK No. 01-14-00982-CR In the Court of Appeals For the First District of Texas At Houston _________________________________________________________ Trial Court Cause No. 13378054 In the 338 th District Court of Harris County, Texas _________________________________________________________ JUAN CARLOS BARRERA-MAGANA, Appellant v.

THE STATE OF TEXAS , Appellee ___________________________________________________________ MOTION FOR EXTENSION OF TIME TO FILE __________________________________________________________

VIVIAN R. KING State Bar No. 00784399 2202 Alabama St. Houston, Texas 77004 (713) 222-2019 Office (877) 753-6706 eFax Appointed Attorney for Appellant *2

TO THE HONORABLE COURT OF APPEALS:

NOW COMES JUAN CARLOS BARRERA-MAGNA, the Appellant

herein, and moves the Court for an extension of time to file Appellant's Brief in this

cause, pursuant to TEX. R. APP. PROC. Rules 10.5 (b)(2) and 38.6(n) , and in

support thereof would show the Court as follows:

I.

The Appellant in this cause was convicted by a jury of Murder in the 338th

District Court of Harris County, Texas in cause number 1338054 and his sentence

was assessed at Life in Prison in the Texas Department of Corrections, Institutional

Division. Notice of Appeal was properly filed on December 04, 2014.

II.

The Clerk’s record was properly filed on January 28, 2015.

The Reporter’s record was filed on February 28, 2015.

Appellant’s brief was due on April 01, 2015.

This is a voluminous record. The case is complicated.

III.

No previous extensions have been filed.

Appellant’s attorney is requesting a 60-day extension of time to file

Appellant’s Brief to June 01, 2015.

IV.

Appellant’s attorney is requesting this extension of time to file Appellant’s

Brief due to multiple trial settings that are demanding an enormous amount of

preparation time.

This motion is not made for delay, but instead, to ensure effective assistance

of counsel.

WHEREFORE, PREMISES CONSIDERED, the undersigned counsel, on

behalf of Appellant, respectfully prays that this Honorable Court grant this extension

to June 01, 2015.

RESPECTFULLY SUBMITTED, /s/ Vivian R. King VIVIAN R. KING Texas Bar No. 00784399 2202 Alabama St.

Houston, Texas 77004 (713) 222-2019 office (877) 753-6706 e Fax VivianRKing@msn.com Email CERTIFICATE OF SERVICE As Attorney of Record for Appellant, I do hereby certify that a true and correct

copy of the above and foregoing document was emailed to Appellate Division and

efiled with the office of the Honorable Devon Anderson, Harris County District

Attorney, on April 10, 2015.

/s/ Vivian R. King