Geneva Doris Vasquez v. State

ACCEPTED
12-14-00283-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
2/4/2015 3:39:36 PM
CATHY LUSK
CLERK

NO. 12-14-00283-CR

ON APPEAL FROM THE 159TH JUDICIAL DISTRICT COURTFILED IN
ANGELINA COUNTY, TEXAS 12th COURT OF APPEALS
TYLER, TEXAS
CAUSE NO. 2014-0421 2/4/2015 3:39:36 PM
CATHY S. LUSK
TH Clerk
GENEVA DORIS VASQUEZ § IN THE 12 COURT OF APPEALS
§
§ OF
vs. §
§
STATE OF TEXAS § TYLER, TEXAS

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

TO THE HONORABLE JUSTICES OF SAID COURT:
Now comes Geneva Doris Vasquez, Appellant in the above styled and
numbered cause, and moves this Court to grant an extension of time to file
appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure,
and for good cause shows the following:
1. This case is on appeal from the 159th District Court of Angelina
County, Texas.
2. The case below was styled the STATE OF TEXAS vs. Geneva Doris
Vasquez, and numbered 2014-00421.
3. Appellant was convicted of Burglary of a Habitation.
4. Appellant was assessed a sentence of Fifteen (15) years Texas
Department of Criminal Justice Institutional Division on August 29, 2014.
5. Notice of appeal was given on September 26, 2014.
6. The clerk's record was filed on October 27, 2014; the reporter's record
was filed on January 5, 2015.
 7. The appellate brief is presently due on February 4, 2015.
8. Appellant requests an extension of time of thirty (30) days from the
present date.
9. No extensions to file the brief have been received in this cause.
10. Defendant is currently incarcerated.
11. Appellant relies on the following facts as good cause for the requested
extension:
Counsel currently has three pending briefs due before the Court including one
he completed and filed on Monday, February 2, 2014 and is therefore respectfully
requesting additional time to review the records and prepare an adequate brief.
Additionally, a supplemental Trial Court Clerk’s Record has been requested by the
Clerk of this Court.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this
Court grant this Motion to Extend Time to File Appellant's Brief, and for such other
and further relief as the Court may deem appropriate.

Respectfully submitted:

/s/John D. Reeves
____________________
John D. Reeves
Attorney at Law
1007 Grant
Lufkin, Texas 75901
Phone (936) 632-160
Fax: (936) 632-1640
tessabellus@yahoo.com
SBOT # 16723000
Counsel for Appellant
 CERTIFICATE OF CONFERENCE

Pursuant to Tex. R. App. 10.1 (5), certify that the staff of the undersigned
conferred with opposing counsel who indicated that she does not oppose this
motion.
/s/John D. Reeves
___________________________
John D. Reeves

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Appellant’s
First Motion to Extend Time to file Appellant’s Brief on this 4h day of February,
2014 forwarded to State’s Attorney, April Ayers-Perez, Assistant District
Attorney, Angelina County, by electronic service at aperez@angelinacounty.net.

/s/John D. Reeves
__________________________
John D. Reeves
Attorney for Appellant,
Geneva Doris Vasquez