ACCEPTED
12-14-00282-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
3/6/2015 2:15:11 PM
CATHY LUSK
CLERK
NO. 12-14-00282-CR
ON APPEAL FROM THE 159TH JUDICIAL DISTRICT COURTFILED IN
ANGELINA COUNTY, TEXAS 12th COURT OF APPEALS
TYLER, TEXAS
CAUSE NO. 2012-0039 3/6/2015 2:15:11 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 Trinity County,
Texas.
2. The case below was styled the STATE OF TEXAS vs. Geneva Doris
Vasquez, and numbered 2012-0039. Appellant was convicted of Fraud.
5. On January 22, 2013, the State filed a Motion to Adjudicate Guilt.
6. Appellant pled “True” to allegations of the State’s Motion to
Adjudication.
7. A pre-sentence investigation was ordered and a sentencing hearing
was conducted . Appellant was assessed a sentence of Two (2) years State Jail on
August 29, 2014.
8. Notice of appeal of was filed on September 26, 2014.
9. The appellate brief is presently due on March 6, 2015.
10. Appellant requests an extension of time of three (3) days from the
present date.
11. One extension to file the brief has been received in this cause.
12. Defendant is currently incarcerated.
13. Appellant relies on the following facts as good cause for the requested
extension:
The above captioned brief is complete excepting editing and proofing. Due to
court schedules, Counsel will be unable to submit the brief by end of business and
therefore requests three days extension.
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 I, the undersigned conferred
with the staff of 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
Motion to Extend Time to file Appellant’s Brief on this 6th day of March, 2015
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