PD-1277-14
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/26/2014 3:34:29 PM
Accepted 12/29/2014 7:57:40 AM
ABEL ACOSTA
COURT OF CRIMINAL APPEALS OF TEXAS CLERK
AUSTIN, TEXAS
NO. PD-1277-14
December 29, 2014
APPEAL COURT NO. 08-12-00261-CR
TRIAL COURT NO. 20050C17647-CC7-1
THE STATE OF TEXAS, *
Respondent, *
*
VS. *
*
JUAN CARLOS REYES *
Petitioner. *
MOTION FOR AN EXTENSION
OF TIME TO FILE PETITIONER’S BRIEF ON THE MERITS
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
COMES NOW, the Petitioner, Juan Carlos Reyes, and files this first motion for
an extension of time to file Petitioner’s Brief on the Merits. Petitioner would show
the Court the following:
(a) Undersigned counsel believed that he had a period of time after the due
date of December 19, 2014 to file his first motion for an extension of
time to file his brief. Because of his heavy workload and through
oversight, undersigned counsel did not realize that he needed to file his
first motions to extend time to file brief on or before the due date of the
brief. Accordingly, undersigned counsel, through mistake and oversight,
did not realize that he was late in filing this first motion to extend time
to file his brief with this Court.
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(b) Complicating matters is the heavy workload that undersigned counsel
had over the previous month. One of the projects he was working on a
Petition for Writ of Certiorari which was filed with the United States
Supreme Court on December 18, 2014 in a case styled Luis Salazar v.
William Sanders and Patricia Sanders. The preparation of this petition
took considerable time.
(b) The Petitioner’s brief petition for discretionary review was due on
December 19, 2014.
(c) This is the Petitioner’s first request for extension of time.
(d) This extension is requested for five (7) days, until December 26, 2014.
PRAYER
WHEREFORE, Petitioner prays that his extension request will be granted until
December 26, 2014
Respectfully submitted,
/s/ James D. Lucas
JAMES D. LUCAS
Attorney for Petitioner
2316 Montana Avenue
El Paso, Texas 79903
Tel: (915) 532-8811
Fax: (915) 532-8807
SBN 12658300
jlucas2@elp.rr.com
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CERTIFICATE OF SERVICE
I, James D. Lucas, hereby certify that on the 26th of December , 2014, a true and
correct amended copy of the foregoing instrument was delivered to the below-named
individuals by electronic means:
Lily M . Strout
Asst. District Attorney
El Paso County Courthouse
500 E. San Antonio, Room 201
El Paso, Texas 79901
tdarnold@ e[county.com
State Prosecuting Attorney
P.O. Box 12405
Austin, Texas 78711
inform ation@ spa.texas.gov
Dated this 26th day of December, 2014.
/s/ Jam es D . Lucas
JAM ES D. LUCAS
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