David Garcia Reyes v. State

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