PD-0680-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
June 8, 2015 Transmitted 6/8/2015 7:48:42 AM
Accepted 6/8/2015 4:18:26 PM
ABEL ACOSTA
NO. PD-0680-15 CLERK
STEVEN HERNANDEZ § IN THE COURT OF
§
vs. § CRIMINAL APPEALS FOR
§
THE STATE OF TEXAS § THE STATE OF TEXAS
MOTION FOR SUSPENSION OF RULES
TO THE HONORABLE COURT OF CRIMINAL APPEALS:
COMES NOW STEVEN HERNANDEZ in the above entitled and numbered
cause and moves this Court, pursuant to Rule 2 of the Texas Rules of Appellate
Procedure, to suspend the timelines allowed in Rules 68.9, 70.1 and 70.2 of the Texas
Rules of Appellate Procedure and order expedited timelines.
This matter centers around the 3rd Court of Appeals’ judgment regarding bond
pursuant to Article 17.151 of the Texas Code of Criminal Procedure.
In light of the fact that this matter solely addresses the matter of bond in a
currently pending matter in the 428th Judicial District Court of Hays County, Texas,
Petitioner moves this Court to reduce the time allowed in TRAP Rule 68.9 to 10 (ten)
days and, in the event the instant petition is granted, reduce the time allowed in TRAP
Rules 70.1 and 70.2 to 15 (fifteen) days.
WHEREFORE, PREMISES CONSIDERED, Petitioner requests this Court to
take notice that the instant matter centers around bond in a matter currently pending in
the 428th Judicial District Court of Hays County, Texas and the 3rd Court of Appeals’
1
judgment and interpretation of Article 17.151 of the Texas Code of Criminal
Procedure and reduce the time allowed for a reply in TRAP Rule 68.9 and, in the
event the instant petition is granted, reduce the time allowed for briefs in TRAP Rules
70.1 and 70.2.
Respectfully submitted,
THE PASTRANO LAW FIRM, P.C.
The Old Cotton Exchange Building
202 Travis Street, Suite 307
Houston, Texas 77002
Telephone: 713.222.1100
Facsimile: 832.218.7114
_____________________________
E. CHEVO PASTRANO
State Bar No. 24037240
chevo@pastranolaw.com
Attorney for Appellant
2
Certificate of Service
I hereby certify that a true and correct copy of the foregoing instrument has
been served on all counsel, listed below, by facsimile, electronic transmission or
hand-delivery, in accordance with Rule 9.5 of the Texas Rules on Appellate
Procedure, on this the 8th day of June, 2015.
Mr. Wes Mau
Hays County District Attorney’s Office
Hays County Government Center, Suite 2057
712 South Stagecoach Trail
San Marcos, Texas 78666
Telephone: (512) 393-7600
Facsimile: (512) 393-7619
Ms. Lisa C. McMinn
State Prosecuting Attorney
P.O. Box 13046
Capital Station
Austin, Texas 78711-3046
Telephone: (512) 463-1660
Facsimile: (512) 463-5724
_____________________________
E. CHEVO PASTRANO
3