ACCEPTED
06-14-00228-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
4/21/2015 1:27:46 PM
DEBBIE AUTREY
CLERK
NO. 06-14-00228-CR
DAVID GARCIA REYES § IN THE COURT OF APPEALS
FILED IN
6th COURT OF APPEALS
VS. § FOR THE SIXTHTEXARKANA,
DISTRICTTEXAS
4/21/2015 1:27:46 PM
THE STATE OF TEXAS § OF TEXAS AT DALLAS
DEBBIE AUTREY
Clerk
ON APPEAL FROM THE
CRIMINAL DISTRICT COURT NO. 3
OF DALLAS COUNTY, TEXAS
IN CAUSE NO. F13-61746-J
APPELLANT’S SECOND MOTION TO EXTEND THE
TIME FOR FILING THE APPELLANT’S BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW the Appellant, David Garcia Reyes, and respectfully requests
that the time for the filing of the Appellant’s brief in the above-styled and
numbered causes be extended. In support of this motion the Appellant would
show the Court the following:
I.
Appellant was convicted of continuous sexual assault of a child and was
sentenced to 15 years’ imprisonment.
II.
The deadline for the filing of the Appellant’s brief is April 21, 2015.
Appellant respectfully requests an extension until May 21, 2015.
III.
One previous extension of time has been granted.
IV.
The facts on which the Appellant relies to reasonably explain the need for
this extension are as follows:
Since the first extension was requested on March 26th, the undersigned
attorney has prepared and filed the brief in Mikroberts, No. 05-14-00994-CR. The
undersigned attorney is currently completing the brief in; Rico, No. 05-14-00251-
CR, which is due on April 22, 2015 pursuant to an order of abatement following
the court reporter’s extremely lengthy delay in filing the record. Following the
Rico brief, the undersigned attorney must prepare the brief in Jackson, No. 05-14-
00297-CR, which is due on April 27, 2015, which is also due pursuant to an order
of abatement following the court reporter’s extremely lengthy delay in filing the
record. Following the Jackson brief, the undersigned attorney will begin work on
the instant case. The undersigned attorney anticipates that it will take a minimum
of two weeks to prepare the brief since the record is well over 1,000 pages long.
WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully
requests that the time for the filing of the Appellant’s brief be extended until May
21, 2015.
Respectfully submitted,
Lynn Richardson /s/ Kathleen A. Walsh
Chief Public Defender Kathleen A. Walsh
Dallas County Assistant Public Defender
State Bar No. 20802200
133 N. Riverfront Blvd., LB-2
Dallas, TX. 75207-4399
(214) 653-3550 (telephone)
(214) 653-3539 (fax)
kwalsh@dallascounty.org
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing motion was served on the
Appellate Division of the Dallas County District Attorney’s office on the 21st day
of April, 2015 by electronic transmission to DCDAAppeals@dallascounty.org.
/s/ Kathleen A. Walsh
Kathleen A. Walsh