Case Information
*0 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 6/29/2015 11:29:28 AM KEITH E. HOTTLE Clerk
*1 ACCEPTED 04-14-00772-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 6/29/2015 11:29:28 AM
KEITH HOTTLE CLERK NO. O4-14-00772-CR JONATHAN JOSE GUILLEN VS. THE STATE OF TEXAS IN THE COURT OF APPEALS FOURTH SUPREME JUDICIAL DISTRICT SAN ANTONIO, TEXAS MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE JUDGE OF SAID COURT COMES NOW the Appellant JONATHAN JOSE GUILLEN, by and through his undersigned attorney, and respectfully requests that this Honorable Court allow him an extension of time for a period of forty—five (45) days in which to file the Appellant's brief. The Appellant makes this request under 38.6(d) of the Texas Rules of Appellate Procedure, and shows the following in support of said motion:
I The clerk’s record in this cause was electronically filed on November 25, 2014. The Court Reporter’s record was electronically filed on April 28, 2015. Appe1lant’s brief is due no later than June 29, 2015. This is Appellant’s second motion for extension of
*2 time. II The Appellant is currently in custody. He was charged with the offense of murder in the 186th Judicial District Court in cause No. 2013CR2647 and was assessed ninety- nine (99) years at TDCJ on October 14, 2014. Counsel was infonned the brief was due on May 28, 2015. The record contains fourteen (14) volumes of testimony and legal documents.
III
This is the second extension requested by the Appellant. The request for more time is being made not for the purposes of delay but rather so that justice may be done. WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully requests that this Court grant an extension of forty-five (45) days for the Appellant to file his Brief in this cause.
Respectfully submitted, CAMPION & CAMPION
<1 ALEX J. so AR1Z3;/ / State Bar 0.177 350 222 E. Main Plaza San Antonio, Texas 78205 Telephone No. 210/227-5161 Telecopier No. 210/229-1243 alex'oss ahoo.com cind cam ionlawfi1m.com
*3 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Motion For Extension of Time To File Brief has on this 29th day of June, 2015, been delivered to the Bexar County District Attorney's Office, San Antoni
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ALEX J. sfl(ARFF
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THE
*4 STATE OF TEXAS
COUNTY
OF BEXAR
BEFORE ME, the undersigned authority, on this day personally appeared ALEX J. SCHARFF and after being duly sworn did depose and state: "My name is ALEX J. SCHARFF. I am familiar with the foregoing Motion For Extension Of Time To File Brief. I have read the foregoing document to which this affidavit is attached and believe the allegations contained therein are true and correct."
4 WITNESS my signature this L 6 day of June, 2015. SUBSCRIBED AND SWORN to before me on this ~ oflune, 2015.
/ALEX J. 92 day @é0t$[4¢ / 3/(Q/1/i/L73 3 U: u, °'"°V MERRVMW Notary Publie/.( in and for -/ My commission Expires fgmuayy 14_ [2013] the State Of Texas
My commission expires: ' /'4 — / 5 *5 CERTIFICATE OF CONFERENCE . gag . . . I certify that on this day of June, 2015, I spoke to Bexar County District Attorney, and advised me that he is not opposed to any extensions of time sought by Appellant.
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