ACCEPTED
No. 14-14-00455-CR
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
2/3/2015 12:38:07 PM
CHRISTOPHER PRINE
CLERK
No. 14-14-00455-CR
In the FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
Court of Appeals 2/3/2015 12:38:07 PM
CHRISTOPHER A. PRINE
For the Clerk
Fourteenth District of Texas
At Houston
_________________________________________________________
Trial Court Cause No. 1406639
In the 185th District Court
of Harris County, Texas
_________________________________________________________
GREGORIO MORENO,
Appellant
v.
THE STATE OF TEXAS,
Appellee
___________________________________________________________
MOTION FOR EXTENSION OF TIME TO FILE
___________________________________________________________
VIVIAN R. KING
State Bar No. 00784399
2202 Alabama St.
Houston, Texas 77004
Tel.: (713) 222-2019
eFax: (877) 753-6706
Email: VivianRKing@msn.com
Appointed Attorney for Appellant
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TO THE HONORABLE COURT OF APPEALS:
NOW COMES GREGORIO MORENO, the Appellant herein, and moves
the Court for an extension of time to file Appellant's Brief in this cause, pursuant to
TEX. R. APP. PROC. Rules 10.5 (b)(2) and 38.6(n), and in support thereof
would show the Court as follows:
I.
The Appellant in this cause pled not guilty in the 185th District Court of
Harris County, Texas in cause number 1406639 plead not guilty and had a jury
trial. The jury found Appellant guilty and sentence was assessed 50 years in the
Texas Department of Corrections, Institutional Division on May 23, 2014. Notice
of Appeal was filed on May 23, 2014.
II.
The Clerk’s record was timely filed.
The Reporter’s record was timely filed.
III.
Appellant’s attorney is requesting an extension of time to file Appellant’s
Brief to February 09, 2015.
IV.
Appellant’s attorney is requesting this extension of time to file Appellant’s Brief
for the following two reasons:
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(1) The record contains over 15 volumes and the undersigned attorney is only
60% through the record.
(2) The undersigned attorney has been unable to complete Appellant’s brief due
to moving her office of 22 years and discovering/firing her secretary for
embezzlement of about $30,000.00 (for which the attorney has not had time to file
charges). 2014 was a rough year but if given more time, Appellant’s brief will be
properly completed.
The Appellant in this case was sentenced to 50 years so I pray this
Honorable Court grants this extension so the undersigned appointed attorney can
properly prosecute this case on appeal.
WHEREFORE, PREMISES CONSIDERED, the undersigned counsel, on
behalf of Appellant, respectfully prays that this Honorable Court grant this
extension to February 09, 2015.
RESPECTFULLY SUBMITTED,
/s/ Vivian R. King
VIVIAN R. KING
Appointed Attorney for Appellant
Texas Bar No. 00784399
2202 Alabama St.
Houston, Texas 77004
(713) 222-2019 office
(877) 753-6706 e Fax
VivianRKing@msn.com. Email
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CERTIFICATE OF SERVICE
As Attorney of Record for Appellant, I do hereby certify that a true and correct
copy of the above and foregoing document was efiled with the office of the
Honorable Devon Anderson, Harris County District Attorney, via the mandatory
electronic filing system on February 03, 2015.
/s/ Vivian R. King
VIVIAN R. KING
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