ACCEPTED
05-14-01400-cr
FIFTH COURT OF APPEALS
DALLAS, TEXAS
3/18/2015 10:55:49 AM
LISA MATZ
CLERK
IN THE
COURT OF APPEALS
FILED IN
FOR THE FIFTH DISTRICT OF TEXAS
5th COURT OF APPEALS
DALLAS, TEXAS
AT DALLAS 3/18/2015 10:55:49 AM
LISA MATZ
Clerk
JOSE DELAPAZ REYES § Appeal No. 05-14-01400-CR
§
VS. §
§
THE STATE OF TEXAS §
MOTION TO EXTEND TIME
TO FILE BRIEF FOR APPELLANT
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW Christian T. Souza (“counsel”) as counsel for
Appellant and respectfully motions this Honorable Court to extend the
time for him to file his Brief for Appellant by 30 days, from March 18,
2015 to April 17, 2015. TEX. R. APP. P. 10.5(b), 38.6(a)(2), and 38.6(d).
In support of this motion counsel shows:
I.
Appellant has not previously requested any extensions. Counsel
has had conflicting obligations since February 17, 2015 that have
included: (1) Petition for Discretionary Review in Cruz Martinez v. State,
Nos. PD-1624-14 and PD-1625-14, filed on February 20, 2015; (2) Brief
for Appellant in Araceli Guzman v. State, Appeal No. 02-14-00297-CR,
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tendered to the Second Court of Appeals of Texas on February 27, 2015;
(3) Reply Brief filed on March 1, 2015 in Stuart Mitchell v. United States of
America, Appeal No. 14-10713, United States Court of Appeals for the
Fifth Circuit; and (4) hearing on March 6, 2015 in District Court in
Midland Texas and other activity relating to indigence status, payment
for record and designation of the record in Arron Castillo v. State, Appeal
No. 11-14-00280-CR, Eleventh Court of Appeals of Texas.
III.
For the foregoing reasons, Appellant respectfully prays for this
Honorable Court to grant a briefing extension of 30 days, from March
18, 2015 to April 17, 2015. TEX. R. APP. P. 10.5(b), 38.6(a)(2), and
38.6(d). Appellant prays for any other relief that this Court would deem
appropriate.
Respectfully Submitted,
/s/ Christian T. Souza
Christian T. Souza
SBN: 00785414
4303 N. Central Expressway
Dallas, Texas 75205
(214) 862-7462
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(214) 696-0867 (fax)
E-Mail: ctsouza@gmail.com
CERTIFICATE OF SERVICE
This is to certify that the Office of the Dallas County Criminal
District Attorney, ATTN. Appellate Division, has or will be
contemporaneously served with a copy of this motion via electronic mail
to DCDAAppeals@dallascounty.org.
/s/ Christian T. Souza
Christian T. Souza
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