PD-0036-15
COURT OF CRIMINAL APPEALS
PD-0036-15 AUSTIN, TEXAS
Transmitted 1/8/2015 9:28:08 AM
Accepted 1/15/2015 4:22:41 PM
MARISOL CARVAJAL-GARCIA ABEL ACOSTA
CLERK
ATTORNEY AT LAW
1600 E. MAIN STREET, SUITE 227
ALICE, TEXAS 78332
361.668.4989 PHONE
361.664.1003 FACSIMILE
January 8, 2015
Via E-FILE JANUARY 15, 2015
Abel Acosta, Clerk of the Court
Court of Criminal Appeals
Supreme Court Building
201 West 14th Street, Room 106
Austin, Texas 78701
Re: Cause No. _______; Enrique Gonzalez, Jr. vs. State of Texas
Dear Mr. Acosta:
In reference to the above-styled cause, enclosed herewith for filing please find
Appellant’s First Unopposed Motion to Extend Time to File Petition for Discretionary Review.
Opposing counsel is being provided with a copy of the same by the method indicated
below.
If you have any questions or concerns, please do not hesitate to contact me.
Sincerely,
/s/ Marisol Carvajal-Garcia
Marisol Carvajal-Garcia
MCG/jac
Enclosure
xc: Enrique Gonzalez, Jr.
Office of the District Attorney Via EMAIL
229th Judicial District
NO. ______________
ENRIQUE GONZALEZ, JR. § IN THE COURT OF
§
VS. § CRIMINAL APPEALS
§
STATE OF TEXAS § OF TEXAS
FIRST UNOPPOSED MOTION TO EXTEND TIME TO
FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUDGES OF SAID COURT:
Now comes Enrique Gonzalez, Jr., Appellant in the above styled and
numbered cause, and moves for an extension of time of 30 days to file a petition for
discretionary review, and for good cause shows the following:
1. On December 10, 2014, the Court of Appeals affirmed appellant's
conviction. Enrique Gonzalez, Jr. v. State, Appellate Cause No. 04-13-00708-CR.
This petition is therefore due on January 9, 2015.
2. Counsel has been unable to complete the petition for the following
reasons: Trial Counsel's law partner was elected Jim Wells County Court at Law
Judge and commenced work on January 1, 2015. Thus trial counsel has acquired a
substantial case load. This Motion is not sought for delay but that justice may be
done.
3. The undersigned conferred with Rumaldo Solis, Jr., Assistant District
Attorney for the 229th Judicial District, who indicated there was no opposition to this
request.
4. Defendant is currently incarcerated.
WHEREFORE, PREMISES CONSIDERED, appellant respectfully
requests an extension of 30 days, i.e. until February 10, 2015, to file a petition for
discretionary review.
Respectfully submitted,
Marisol Carvajal-Garcia
Attorney at Law
1600 E. Main St., Suite 227
Alice, Texas 78332
Tel: 361.668.4989
Fax: 361.664.1003
By: /s/ Marisol Carvajal-Garcia
Marisol Carvajal-Garcia
State Bar No. 24065014
marisolcarvajal@hotmail.com
Attorney for Enrique Gonzalez, Jr.
CERTIFICATE OF SERVICE
This is to certify that on January 8, 2015, a true and correct copy of the above
and foregoing document was served on the District Attorney's Office, Duval
County, P.O. Drawer 1061, San Diego, Texas 78384, by E-mail.
/s/ Marisol Carvajal-Garcia
Marisol Carvajal-Garcia