Case Information
*1 ACCEPTED 04-15-00240-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 11/3/2015 12:26:52 PM KEITH HOTTLE CLERK NO. 04-15-00240-CR MARIO JESUS RAMIREZ § IN THE FOURTH COURT
Appellant §
vs. § OF APPEALS AT
§ THE STATE OF TEXAS, § SAN ANTONIO, TEXAS
Appellee §
FIRST MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
Comes Now, Mario Jesus Ramirez, Appellant, and files this Motion for Extension of Time to File Appellant’s Brief under Rules 10.5(b) and 38.6(d) of the Texas Rules of Appellate Procedure, and would show:
I. The deadline for filing Appellant’s brief is November 2, 2015. Appellant has received no previous extensions of time to file his brief.
II. Appellant hereby requests a sixty-four (64) day extension of time to file his brief until January 5, 2016. This request is based on the following: Appellant’s attorney, the undersigned, was hospitalized two days in
October. *2 2. The undersigned attorney has had difficulty securing a copy of the
Reporter’s Record from Amy Hinds, the individual who was the Official Court Reporter during Appellant’s case. Ms. Hinds left her employment with the 379 th District Court of Bexar County, Texas without filing a copy of the Reporter’s Record with the Bexar County District Clerk’s office. The only contact information the 379 District Court had for her was an e-mail address. Ms. Hinds has now promised to send a copy of the Reporter’s Record, but the undersigned has not as yet received it.
3. The undersigned attorney will have a visit this month from out-of-state
relatives who made travel plans months in advance. This is a serious case in which Appellant was sentenced to Life
imprisonment and a $10,000.00 fine. The extension requested herein is necessary to accord him with effective assistance of counsel on appeal.
WHEREFORE, PREMISES CONSIDERED, Appellant requests that this Court grant a sixty-four (64) day extension of time to file his brief until January 5, 2016.
Respectfully submitted, Attorney for Defendant on Appeal 1108 Lavaca, #110-221 Austin, TX 78701 *3 (512)445-4504 (512)478-2318 (fax) warrentucker@grandecom.net State Bar No. 11199600 CERTIFICATE OF SERVICE This is to certify that I sent a true and correct copy of the foregoing to Nico LaHood, Criminal District Attorney, at Paul Elizondo Tower, 101 W. Nueva, 7 Floor, San Antonio, TX 78205, by regular mail on this 3 rd day of November, 2015.
/s/ Connie J. Kelley Connie J. Kelley CERTIFICATE OF COMPLIANCE
This is to certify that the foregoing document is in 14 point font. The word count is 264 words, which is in compliance with T.R.A.P. Rule 9.4.