Fernando Saucedo v. State

ACCEPTED 12-13-00368-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 5/13/2015 8:37:02 AM CATHY LUSK CAUSE NO. 12-13-00368-CR CLERK FERNANDO SAUCEDO § IN THE § VS. § TWELFTH COURT FILED IN § 12th COURT OF APPEALS THE STATE OF TEXAS § OF APPEALS TYLER, TEXAS 5/13/2015 8:37:02 AM MOTION TO CATHY S. LUSK Clerk CORRECT CALENDAR SCHEDULE TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Appellant in the above styled and numbered cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the 114th Judicial District Court of Smith County, Texas. 2. The case below was styled State v. Fernando Saucedo and numbered 114-1144- 13. 3. Appellant was convicted of Driving While Intoxicated. 4. Appellant was assessed a sentence of twenty (20) years confinement in the Texas Department of Criminal Justice-Institutional Division. 5. Notice of Appeal was given on November 25, 2013. 6. The Clerk's Record was filed on December 10, 2013; the Reporter's Record was filed on March 12, 2014. 7 The Appellant’s Brief is currently due on June 15, 2015. However, the Court sent the notice to Mr. Saucedo at the Hutchins Unit. As of this morning, May 13, 2015, he is still being held in the Smith County Jail on the bench warrant issued from the 114th District Court. 8. On behalf of his client, Counsel requests the Court withdraw the order from May 12, 2015, and calculate a new date for the completion fo the brief, bearing in mind that at best the Smith County Jail has a very rudimentary law library and because he has been removed from his unit for so long, there is a possibility that he will be sent first to the Gurney Unit for intake.and 10. Appellant prays that this Court grant this Motion to Extend Time to File Appellant’s Brief for a period of sixty (60) days, and for such other and further relief as the Court may deem appropriate. Respectfully submitted, Law Office of James W. Huggler, Jr. 100 E. Ferguson, Suite 805 Tyler, Texas 75702 Tel: (903) 593-2400 Fax: (903) 593-3830 By: /s/ James Huggler James W. Huggler, Jr. State Bar No. 00795437 Attorney for APPELLANT CERTIFICATE OF SERVICE This is to certify that on May 13, 2015, a true and correct copy of the above and foregoing document was served on Michael West, Smith County District Attorney's Office, 100 North Broadway, Tyler, Texas 75702, by regular mail, fax, hand delivery, or electronic filing, and Mr. Fernando Saucedo at the Smith County Jail. /s/ James Huggler James W. Huggler, Jr.