in the Matter of A. A. R., a Juvenile

ACCEPTED 08-15-00051-cv 08-15-00051-CV EIGHTH COURT OF APPEALS EL PASO, TEXAS 9/9/2015 1:54:05 PM DENISE PACHECO CLERK NO. 08-15-00051-CV FILED IN COURT OF APPEALS 8th COURT OF APPEALS EIGHTH SUPREME JUDICIAL DISTRICT EL PASO, TEXAS 9/9/2015 1:54:05 PM EL PASO, TEXAS DENISE PACHECO _______________________________________________________Clerk IN THE MATTER OF A.A.R., D.O.B. 09/16/99, A JUVENILE, APPELLANT v. THE STATE OF TEXAS, APPELLEE _______________________________________________________ On Appeal from 65th Judicial District Court El Paso County, Texas, Cause No. 1400329 ______________________________________________________ APPELLEE’S FIRST MOTION TO EXTEND TIME FOR FILING BRIEF _______________________________________________________ TO THE COURT OF APPEALS: COMES NOW THE STATE OF TEXAS, APPELLEE, and files this Appellee’s First Motion to Extend Time for Filing Brief with this Honorable Court and in support would show the following: 1. This is an appeal from a judgment of the 65th Judicial District Court in Cause No. 1400329 styled In the Matter of A.A.R. Appellee’s First Motion for Extension of Time Page 1 2. Appellee’s brief is due on September 13, 2015. 3. Appellee seeks an extension because counsel’s other professional commitments have interfered with his ability to complete the brief by September 13, 2015. In addition the legal issues raised in Appellant’s Brief require additional time to research and to submit in a brief of professional quality. 4. An extension until Tuesday, October 13, 2015 is requested. WHEREFORE, Appellee requests that the Court enter an order extending the time for filing Appellee’s brief to the 13th day of October, 2015. Respectfully submitted, JO ANNE BERNAL COUNTY ATTORNEY 500 E. San Antonio, Room 503 El Paso, Texas 79901 (915) 546-2050 - Telephone (915) 546-2133 – Telecopier By: /s/ Ralph Girvin RALPH GIRVIN Assistant County Attorney Texas Bar No. 00795376 CERTIFICATE OF SERVICE I hereby certify that on this day, September 9, 2015, a true and correct copy of the foregoing motion was faxed to Veronica Lerma, counsel for the Appellant, to fax number (915) 533-7236. /s/ Ralph Girvin RALPH GIRVIN Appellee’s First Motion for Extension of Time Page 2 CERTIFICATE OF CONFERENCE I hereby certify that the undersigned conferred with Veronica Lerma, attorney for the Appellant regarding, who then advised that she has no opposition an extension for filing Appellee’s Brief. /s/ Ralph Girvin RALPH GIRVIN Appellee’s First Motion for Extension of Time Page 3