ACCEPTED
04-14-00372-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
1/22/2015 5:26:35 PM
KEITH HOTTLE
CLERK
NO. 04-14-00372-CR and 04-14-00370-CR
ANDRES RAMON JUAREZ § IN THE FOURTH DISTRICT
FILED IN
4th COURT OF APPEALS
§ SAN ANTONIO, TEXAS
§ 1/22/2015 5:26:35 PM
VS. § COURT OF APPEALS
KEITH E. HOTTLE
§ Clerk
§
STATE OF TEXAS § SAN ANTONIO, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE STATE’S BRIEF
TO THE HONORABLE JUDGES OF THE FOURT COURT OF APPEALS:
NOW COMES Nicholas “Nico” LaHood, Criminal District Attorney of
Bexar County and Counsel for the State of Texas, and files this Motion asking that
the Court extend the time for filing the State’s brief.
Appellant pled no contest to two aggravated robbery indictments on
February10, 2014. On April 28, 2014, after hearing evidence from both sides, the
trial court sentenced appellant to 45 years in the Texas Department of Criminal
Justice. Appellant filed a notice of appeal on May 14, 2014. The reporter’s record
was filed on June 3, 2014. Appellant’s original appointed counsel filed an Ander’s
brief on November 10, 2014, noting there was no meritorious issues to present to
the court. The appellant filed a pro se Motion for a Constitutional Review of
Appellate Motion to Withdraw as Counsel in Appellant’s Appeal. The State’s brief
was due January 17, 2015. This is the State’s first motion for extension and the
State requests a 30 day extension to February 16, 2015.
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This extension is not sought for the purpose of delaying this appeal. State
requests an extension for the following reasons:
1) Counsel would like more time to research and write the State’s brief.
The appellant’s motion makes allegations without support or benefit of
the record, and the State needs more time to respond appropriately.
2) Counsel has been working on the following appeal:
a. In re J.B., 04-14-0079-CV
b. Paulino Flores v. State, 04-14-00315-CR
3) Counsel recently filed the following briefs in the First Court of Appeals:
a. Roland Alvarado v. State, 01-14-00547-CR
4) Counsel recently filed the following briefs in the Fourth Court of
Appeals:
a. Filiberto Sierra v. State, 04-14-00279-CR
a. In re K.B.F. and Z.A.R., 04-14-004392-CV
b. Frances Rosalez Ford v. State, 04-14-00025-CR
c. Mark Anthony Garcia v. State, 04-13-00818-CR
d. Arthur Thomas v. State, 04-14-00025-CR
e. In re C.H.R., a juvenile, 04-14-00336-CV
f. State v. Robert Romo, 04-14-00197-CR
Therefore, counsel respectfully asks the Court to grant this extension time
to file the State’s brief in this case.
WHEREFORE, PREMISES CONSIDERED, Counsel for the State prays
that the Court grant an extension of time to February 16, 2015 for filing the State’s
brief.
Respectfully submitted,
Nicholas “Nico” LaHood
Criminal District Attorney
Bexar County, Texas
/s/ Lauren A. Scott
_____________________
Lauren A. Scott
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State Bar No. 24066843
Assistant Criminal District Attorney
101 W. Nueva Street
San Antonio, Texas 78205-3030
Phone: (210) 335-2314
Fax: (210) 335-2436
CERTIFICATE OF SERVICE
I, Lauren A. Scott, Assistant District Attorney, Bexar County, Texas, certify
that a copy of the foregoing motion was delivered by mail to the appellant at the
Bexar County jail on January 23, 2015.
_/s/ Lauren A. Scott
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