ACCEPTED
04-14-00772-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
7/16/2015 1:38:32 PM
KEITH HOTTLE
CLERK
NO. 04- l4-00772-CR
FILED IN
4th COURT OF APPEALS
JONATHAN JOSE GUILLEN SAN ANTONIO, TEXAS
7/16/2015 1:38:32 PM
VS. KEITH E. HOTTLE
Clerk
THE STATE OF TEXAS
IN THE COURT OF APPEALS
FOURTH SUPREME JUDICIAL DISTRICT
SAN ANTONIO, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUDGE OF SAID COURT
COMES NOW the Appellant JONATHAN JOSE GUILLEN, by and through his
undersigned attorney, and respectfully requests that this Honorable Court allow him an
extension of time for a period of thirty (30) days in which to file the Appellant's brief.
The Appellant makes this request under 38.6(d) of the Texas Rules of Appellate
Procedure, and shows the following in support of said motion:
I
The c1erk’s record in this cause was electronically filed on November 25, 2014.
The Court Reporter’s record was electronically filed on April 28, 2015. Appe1lant’s brief
is due no later than July 16, 2015. This is Appellant’s third motion for extension of time.
ll
The Appellant is currently in custody. He was charged with the offense of murder
in the 186th Judicial District Court in cause No. 2013CR2647 and was assessed ninety—
nine (99) years at TDCJ on October 14, 2014. Counsel was informed the brief was due
on May 28, 2015. The record contains fourteen (14) volumes of testimony and legal
documents.
III
This is the third extension requested by the Appellant. The request for more time
is being made not for the purposes of delay but rather so that justice may be done.
IV
Since the brief was due, counsel has completed thirty-seven pages of the Statement
of Facts and made notes of sixteen potential points of error, which still need to be
researched, and either included or excluded. Since the entry of the last Court's order
granting an extension, counsel has worked overtime and on weekends to focus on the
completion of the brief, but also to effectively represent all other clients, in State and
Federal courts, in and out of jails, inside and outside of Bexar County Courts, as well as
assisting a colleague, who recently underwent a very serious surgery, with his cases. The
undersigned also has to return phone calls and make time for other cases and court
appearances. The undersigned is asking for a thirty (30) day extension but believes that
the brief will be completed before then. This particular case is fact-intensive with many
exhibits, pictures, as well as long videos and telephone calls.
WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully requests
that this Court grant an extension of thirty (30) days for the Appellant to file his Brief in
this cause.
Respectfully submitted,
CAMPION & CAMPION
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’ALEX J. 2?/PIA1iF%
State Bar 0. 1772 5
222 E. Main Plaza
San Antonio, Texas 78205
Telephone No. 210/227-5161
Telecopier N0. 210/229-1243
alex'ossc ahoo.com
cind cam ionlawfirmcom
CERTIFICATE OF SERVICE
This is to ceitify that a true and correct copy of the foregoing Motion For
Extension of Time To File Brief has on this 16th day of July, 2015, been delivered to the
Bexar County District Atton1ey's Office, San Antonio, Texas.
4
KLEX J. /§i4ARFF / fl
THE STATE OF TEXAS
COUNTY OF BEXAR
BEFORE ME, the undersigned authority, on this day personally appeared ALEX J .
SCHARFF and after being duly sworn did depose and state:
"My name is ALEX J. SCHARFF. I am familiar with the foregoing Motion For
Extension Of Time To File Brief. I have read the foregoing document to which this
affidavit is attached and believe the allegations contained therein are true and correct."
WITNESS my signature this if; day of July, 20 1
/ (
SUBSCRIBED AND SWORN to before me on this [I
day ofJuly, 2015.
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My commission Expires Notary Publicfin and for
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CERTIFICATE OF CONFERENCE
I certify that on this day of July, 2015, I spoke to Bexar County District
Attorney, and advised me that he is not opposed to any extensions of time sought by
Appellant.
,4(LEX’J. RFF
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