David Garcia Reyes v. State

ACCEPTED 06-14-00228-CR SIXTH COURT OF APPEALS TEXARKANA, TEXAS 3/26/2015 1:02:20 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 3/26/2015 1:02:20 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 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 March 19, 2015. Appellant respectfully requests an extension until June 17, 2015. III. No previous extension of time has been requested. IV. The facts on which the Appellant relies to reasonably explain the need for this extension are as follows: The undersigned attorney is currently working on the brief in Mikroberts, No. 05-14-00994-CR. Once the brief in Mikroberts has been filed, and before work can begin on the instant case, the undersigned attorney must prepare the briefs in; Rico, No. 05-14-00251-CR; Jackson, No. 05-14-00297-CR; Hunter, No. 05-14-01146-CR; and Dickson, No. 05-14-01496-CR, all of which are currently on more than one extension. The undersigned attorney is requesting an extension of 90 days due to the fact that the records in each of the foregoing cases is rather lengthy and the undersigned attorney anticipates being unable to start work on the instant case until the last week of May. Furthermore, the record in the instant case is also lengthy, 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 June 17, 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 26th day of March, 2015 by electronic transmission to DCDAAppeals@dallascounty.org. /s/ Kathleen A. Walsh Kathleen A. Walsh