NOW COMES JOHN ESQUIVEL, Appellant, by and through their attorney, Amber

Vazquez Bode, and file this Second Motion for Extension of Time to File Appellant's Brief. In support thereof Appellant offers as follows:

1. According to the Texas Rules of Appellate Procedure Rule 38.6 Time to File Briefs: "(a) Appellant's Filing Date. Except in a habeas corpus or bail appeal, which is governed by Rule 31, an appellant must file a brief within 30 days-20 days in an accelerated appeal-after the later of:

( 1) The date the clerk's record was filed; or (2) The date the reporter's record was filed."

2. The Reporter's Record was filed on October 8, 2015. 3. The appellant's brief is due on December 9, 2015. 4. The Appellant cites the following facts and reasons to the Court as Justification

for this Second Motion for Extension: *2 a) Counsel just got out of a felony trial on December 3, 2015 in the 368th District Court in Williamson County Texas, Cause No. 14-1915-K368. Furthermore counsel '

is needing an extension to gather research and was unable to gather all research due to

the felony trial last week.

5. Appellant hereby requests an extension of 30 days due to the stated reasons. 6. Appellant respectfully requests a brief extension of 30 days in order to receive

proper research for the case. The Appellant respectfully requests that this court GRANT the Second Motion for Extension of Time to File Appellant's Brief.

R

A azquez Bode State Bar No. 24039225 The Vazquez Law Firm 1004 West Ave. Austin, Texas 78701 (512) 220-8507 (telephone) (512) 480-0760 (facsimile)

COUNSEL FOR APPELLANT

CERTIFICATE OF SERVICE

*3 I, AMBER VAZQUEZ BODE, Attorney for Appellant, do hereby certify that a true and correct copy of the above and foregoing Second Motion for Extension of Time to File Appellant's Brief has been served electronically on Third Court of Appeals Price Daniel Sr. Bldg. 209 West 14th Street, Room 101 Austin, Texas 78701 Ms. Angela Chambers 299th District Court Official Court Reporter 299th Judicial District Court Blackwell-Thurman Justice Center 509 West 11th Street- 8th Floor Austin, Texas 78701 Travis County District Attorney Appellate Division 509 West 11th Street Austin, Texas 78701 Travis Count~ District Clerk 509 West 11 t Street, Room 1.400 Austin, Texas 78701 The Honorable Karen Sage 299th District Court Blackwell-Thurman Justice Center 509 West 11th Street- 8th Floor Austin, Texas 78701