ACCEPTED
04-14-00181-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
1/2/2015 12:37:15 PM
KEITH HOTTLE
CLERK
CAUSE NO. 04-14-00181-CR
MICHAEL RIVAS § IN THE FOURTH COURT
FILED IN
§ 4th COURT OF APPEALS
VS. § OF APPEALS SAN ANTONIO, TEXAS
§ 1/5/2015 9:01:00 AM
STATE OF TEXAS § SAN ANTONIO, KEITH E. HOTTLE
TEXAS
Clerk
MOTION TO EXTEND TIME TO FILE APPELLEE’S BRIEF
TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes the 38th Judicial District Attorney, Appellee, in the above –entitled and -
numbered cause, and moves this Court to grant an extension of time to file appellee's brief, pursuant
to Rule 38.6 and 10.5 of the Texas Rules of Appellate Procedure, and for good cause shows the
following:
1. This case is on appeal from the 38th Judicial District Court of Medina County, Texas.
2. The case below was styled the State of Texas vs. Michael Rivas, and numbered 12-04-
10954-CR.
3. The Appellant’s brief was filed on December 1, 2014.
4. The Appellee’s brief is due on or about January 2, 2015.
5. The State of Texas requests a ninety (90) day extension to file its brief.
6. This is the state’s first request for an extension to file its brief.
10. The state needs additional time to properly prepare, research, and file its reply brief.
WHEREFORE, PREMISES CONSIDERED, Appellee prays that this Court grant this
Motion To Extend Time to File Appellee's Brief, and for such other and further relief as the Court
may deem appropriate.
Respectfully submitted,
DANIEL J. KINDRED
38TH JUDICIAL DISTRICT ATTORNEY
MEDINA COUNTY, TEXAS
3102 Avenue G
Hondo, Texas 78861
Telephone: (830) 741-6188
Facsimile: (830) 741-6033
By: /s/ Christina Busbee
CHRISTINA BUSBEE
State Bar No. 00797819
ASSISTANT DISTRICT ATTORNEY
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing MOTION TO EXTEND
TIME TO FILE APPELLEE’S REPLY BRIEF was served on MICHAEL C. GROSS, GROSS & ESPARZA,
P.L.L.C. at 106 SOUTH ST. MARY’S STREET, SUITE 260, SAN ANTONIO, TEXAS 78205, via
electronic mail address, lawofcmg@gmail.com on January 2, 2015.
/s/ Christina Busbee
CHRISTINA BUSBEE