Geneva Doris Vasquez v. State

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