Case Information
*0 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 11/13/15 3:50:25 PM KEITH E. HOTTLE Clerk *1 ACCEPTED 04-14-00904-cr FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 11/13/2015 3:50:25 PM KEITH HOTTLE CLERK No. 04-14-00904-CR
IN THE COURT OF APPEALS
FIRST COURT OF APPEALS DISTRICT OF TEXAS
HOUSTON, TEXAS
____________________________________________________________
JOHNATHAN MATTHEW ESCOBEDO,
Appellant v.
THE STATE OF TEXAS,
Appellee ______________________________________________________________________________
On Appeal from the 81 st /218 th District Court
Atascosa County, Texas
Cause Number 13-09-0117-CRA
______________________________________________________________________________
STATE’S MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
______________________________________________________________________________
Rene M. Pena / 218 Tele: (830) 393-2200 Fax: (830) 393-2205 E-Mail: marcledet@81stda.org State Bar No. 24002459 Attorneys for the State of Texas *2
TATE ’ S F IRST OTION F OR E XTENSION O F IME O F ILE RIEF The State of Texas, under the authority of Rules 10.5(b) and 38.6(d), Texas Rules
of Appellate Procedure asks the Court to extend time to file the State’s Brief from
NOVEMBER 13, 2015, up to and including NOVEMBER 20, 2015, a period of seven (7)
days.
1. Appellant was found guilty in Atascosa County, Texas for Murder.
2. The State’s Brief is presently due on NOVEMBER 13, 2015.
3. The State of Texas respectfully requests an additional seven (7) days to file its
brief, that is, an extension of time until November 20, 2015.
4. Only one previous extension has been requested by the State, and this its second\
and last extension, is only for 7 days more.
5. The State of Texas requests this extension based on the following reasons: The 81 Judicial District Attorney’s Office covers five (5) counties and
A.
over two hundred miles. Our office does not have an appellate section.
All appellate work is done at times when prosecutors are not in court, not
preparing for trial, or not preparing for grand jury.
B. The State was delayed in receiving a copy of Appellant’s brief and also has
a special Grand Jury scheduled for Monday, November 16, 2106.
C. For these reasons, the State asks the Court to grant an extension of thirty
(30) days to November 13, 2015, within which the State may file its brief
in this cause.
Respectfully submitted, Rene M. Pena T T EXAS B AR N UMBER 00792752 /S/ ARC L EDET Telephone (830) 393-2200 Telecopier (830) 393-2205 EXAS AR N UMBER 24002459 Attorneys for the State of Texas Certificate of Service
I hereby certify that the above and foregoing was sent to Richard Langlois, 217
Ardent Grove, San Antonio, TX 78215 on the 13 day of November, 2015 in accordance
with the Texas Rules of Procedure.
/S/ Marc Ledet