Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/9/2015 3:05:16 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00178-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 7/9/2015 3:05:16 PM CHRISTOPHER PRINE CLERK NO. 01-15-00178-CR IN THE COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS AT HOUSTON JUAN REYES, Appel/ant, v.

THE STATE OF TEXAS, Appel/ee. Appealed from the 184 District Court of Harris County, Texas Trial Court Cause Number 1313736 MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Joseph Salhab State Bar #17532300 2028 Buffalo Terrace Houston, Texas 77019 Tel. (713) 528-1005 Fax: (713) 528-2424 josephsalhab@mindspring.com COUNSEL FOR APPELLANT JUAN REYES *2 NO. 01-15-00178-CR IN THE COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS AT HOUSTON JUAN REYES, Appellant, v.

THE STATE OF TEXAS, Appellee. Appealed from the 184 District Court of Harris County, Texas Trial Court Cause Number 1313736 MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, JUAN REYES, Appellant, by and through his attorney

of record on appeal, Joseph Salhab, files this Motion for Extension of Time

to File Appellant's Brief. In support of said Motion, the Appellant shows the

Court the following:

I.

The Appellant was convicted in the 184 th District Court of Harris

County, Texas, on or about February 12, 2015 in Cause Number 1313736,

of Capital Murder and sentenced to life imprisonment without the possibility

of parole. Appellant gave timely notice of appeal.

II.

Appellant's brief was originally due on July 9, 2015. This is

Appellant's first Motion for Extension.

III.

Appellant is requesting the Court grant an extension of forty-five (45)

days for filing the Appellant's Brief until August 23, 2015.

IV.

Appellant's request for an extension of time is based on the fact that

he is engaged in numerous other trial and appellate cases. Significant

cases include:

The State of Texas v. Marquisha A. Williams, in the 248 th District

Court of Harris County, Texas. Defendant is charged with

Capital Murder. The case was set for May 26, 2015.

The State of Texas v. Ricky Gaines, in the 184 District Court of

Harris County, Texas. Defendant is charged with Aggravated

Assault. The case is set for July 14, 2015.

The State of Texas v. Byron Chatman, in the 184 th District Court,

Harris County, Texas. Defendant is charged with Burglary of a

Habitation. The case is set for July 14, 2015.

The State of Texas v. Ronald Haskell, in the 248 th District Court of

Harris County, Texas. Defendant is charged with Capital

Murder. The case was set April 22, 2015. Change of venue

hearing was set for June 24, 2015.

The State of Texas v. Wilbert Lewis, in the 183 rd District Court of

Harris County, Texas. Defendant is charged with Aggravated

Robbery. The case is set for jury trial July 15, 2015.

The State of Texas v. Merrick West, in the 338 District Court of

Harris County, Texas. Defendant was charged with Aggravated

Robbery. The case is set for July 23,2015.

James Rivera v. The State Of Texas, in the 14th Court of Appeals of

Houston, Texas. Appellant brief was filed May 8, 2015.

Ralph Garcia, Jr. v. The State of Texas, in the 1 st Court of Appeals of

Galveston, Texas. Appellant brief was filed June 24, 2015.

Additionally, Appellant's attorney is involved in numerous other trial

and appellate cases, not listed here.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that the

Court grant an extension of forty-five (45) days, until August 23, 2015, to

file Appellant's Brief.

Respectfully submitted, ~c~ JSa i t lab ------- State Bar #17532300 2028 Buffalo Terrace Houston, Texas 77019 Tel. (713) 528-1005 Fax: (713) 528-2424 josephsalhab@mindspring.com COUNSEL FOR THE APPELLANT JUAN REYES CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing motion notice of electronic filing (NEF), on the +- day of was delivered to Assistant District Attorney for Har~, Texas, via , 2015.

c= ~4~ JOALHAB ' - *6 VERIFICATION § STATE OF TEXAS

§ §

COUNTY OF HARRIS

BEFORE ME, the undersigned authority on this day personally appeared

JOSEPH SALHAB, who being duly sworn has deposed and stated upon

oath:

"My name is JOSEPH SALHAB. I am the Appel/ant's attorney

on appeal in the above-styled and numbered cause. I have

read the above and foregoing Motion to Extend Time to file

Appel/ant's Brief and the facts contained therein are true and

correct." SUBSCRIBED AND SWORN TO BEFORE ME, the -:::Tu-fj

undersigned authority, on this the 7 'fJ. day of , 2015, to

certify which, witness my hand and official seal of office. .. S*ill:?P.RYlEE APPLEWHITE \'1" M'i COMMiSSION EXPIRES M'A_J.18 2017 .;'.:' ~'/;-l'

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