ACCEPTED
04-14-00670-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
8/5/2015 4:28:45 PM
KEITH HOTTLE
CLERK
No. 04-14-670-CR
STATE OF TEXAS § IN THE COURT OF APPEALS
FILED IN
4th COURT OF APPEALS
VS. § FOURTH JUDICIAL DISTRICT
SAN ANTONIO, TEXAS
08/05/15 4:28:45 PM
SIMON RENE GARCIA § BEXAR COUNTY,
KEITHTEXAS
E. HOTTLE
Clerk
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE REPLY BRIEF
From the 175th District Court of Bexar County, Texas
Trial Court No. 2012-CR-10101
Hon. Mary Roman, Judge Presiding
In accordance with Tex. R. App. Pro. 10.5(b)(1), the undersigned counsel submits his
“Unopposed Motion for Extension of Time to File Reply Brief,” and shows as follows:
This Court’s current briefing deadline is Thursday, August 6th, 2015. Since the filing of
the State’s response brief, the undersigned has filed the following:
On Friday, July 31, 2015, Counsel filed a reply brief with this Court in State v. Luis
Arnaldo Baez, Cause No. 04-14-00374-CR;
On Wednesday, July 22, 2015, Counsel filed a petition for discretionary review (Cause
No. PD-0756-15), with the Texas Court of Criminal Appeals, stemming from the San Antonio,
Fourth Court of Appeals decision in Arrington v. State, 2015 Tex. App. LEXIS 2529 (Tex. App.
San Antonio Mar. 18, 2015), involving four 60 and one 20 year (concurrent) sentences for sexual
assault-related convictions;
Counsel has pretrial motions due to be filed no later than August 10th, 2015, in State v.
Shawn Dillard, Cause No. 2015-CR-5293A, pending in the 290th D. Ct. of Bexar County, Texas,
a capital murder prosecution in which the State (at least currently), has announced that they will
seek the death penalty.
Counsel has prepared for a hearing, which is scheduled before the Hon. Pamela Mathy,
on Thursday, August 6th, 2015 @ 9:30 a.m, in United States v. Shepherd, Cause No. SA:12-CR-
643-XR, involving a 28 U.S.C. § 2255 petition.
On Tuesday, August 4th, 2015, the undersigned counsel consulted with Ms. Mary
Beth Welsh, Asst. Dist. Atty. with the Appellate Division of the Bexar County District
Attorneys Office, who informed that she had no opposition to the requested extension of
time.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this
Court grant the requested 12-day extension of time to file his reply brief, to and including
Monday, August 17, 2015.
Respectfully submitted,
Jorge G. Aristotelidis
Tower Life Building
310 South St. Mary’s Street, Suite 1830
San Antonio, Texas 78205
210/277-1906
jgaristo67@gmail.com
By: /s/ JORGE G. ARISTOTELIDIS
SBN: 00783557
CERTIFICATE OF SERVICE
I hereby certify that on this the 5th of August, 2015 a copy of the foregoing “Unopposed
Motion for Extension of Time to file Reply Brief” has been delivered to the Appellate Section of
the Bexar County District Attorney’s Office, via email.
/s/ JORGE G. ARISTOTELIDIS