ACCEPTED
08-14-00153-CR
EIGHTH COURT OF APPEALS
08-14-00153-CR EL PASO, TEXAS
3/25/2015 2:19:32 PM
DENISE PACHECO
CLERK
NO. 08-14-00153-CR
IN THE FILED IN
8th COURT OF APPEALS
COURT OF APPEALS EL PASO, TEXAS
EIGHTH DISTRICT OF TEXAS 3/25/2015 2:19:32 PM
DENISE PACHECO
Clerk
RICARDO ZUNIGA APPELLANT
V.
THE STATE OF TEXAS APPELLEE
STATE’S SECOND MOTION
FOR AN EXTENSION OF TIME TO FILE THE STATE’S BRIEF
TO THE COURT OF APPEALS, EIGHTH DISTRICT OF TEXAS:
COMES NOW, the State of Texas in the above styled and numbered cause,
pursuant to Rule 10.5(b) and Rule 38.6(d) of the Texas Rules of Appellate
Procedure, and requests an extension of time in which to file the State’s brief, and
would show the Court as follows:
1. The State’s brief was due to be filed on March 23, 2015.
2. This extension is requested for 30 days until April 22, 2014.
3. This is the State’s second motion for an extension of time.
4. The undersigned attorney for the State has been unable to complete
the State’s brief in a timely manner during the briefing period and
requests this extension due to the following factors:
(a) The undersigned was researching and reviewing this Court’s opinion in
State v. Gendron, No. 08-13-00119-CR, for the possible filing of a petition
for discretionary review. The undersigned assisted the State Prosecuting
Attorney’s Office and that office filed the petition for discretionary review.
(b) The undersigned was a speaker for the District Attorney’s Office at the
annual Conference on Crimes Against Women held in Dallas, Texas, on
March 16-18, 2015. The presentations required extensive research and
preparation.
(c) The undersigned presented oral argument to this Court on March 5,
2015, in Engleton v. State, 08-13-00077-CR. The undersigned did not
prepare the State’s brief in the case and was required to research and review
the case in preparation for oral argument.
(d) The undersigned has been actively assisting the domestic violence unit
of the District Attorney’s Office in case screening and evaluation, and trial
research.
PRAYER
WHEREFORE, the State prays that its extension request will be granted
until April 22, 2015.
Respectfully submitted,
JAIME ESPARZA
DISTRICT ATTORNEY
34th JUDICIAL DISTRICT
/s/ Joe Monsivais
JOE MONSIVAIS
ASST. DISTRICT ATTORNEY
201 EL PASO COUNTY COURTHOUSE
500 E. SAN ANTONIO
EL PASO, TEXAS 79901
(915) 546-2059 ext. 3308
FAX (915) 533-5520
SBN 00795537
jomonsivais@epcounty.com
ATTORNEYS FOR THE STATE
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CERTIFICATE OF SERVICE
The undersigned certifies that on March 25, 2015, a copy of the foregoing
State’s motion was delivered by electronic mail to the attorney for appellant,
Ruben Morales, by utilizing the E-serve system at:
rbnpmrls@gmail.com
/s/ Joe Monsivais
JOE MONSIVAIS, A.D.A.
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