ACCEPTED
04-14-00626-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
1/26/2015 3:56:17 PM
KEITH HOTTLE
CLERK
NO. 04-14-00626-CR
FILED IN
4th COURT OF APPEALS
ALVIN VALADEZ, JR., § COURT OF APPEALS
SAN ANTONIO, TEXAS
Appellant 1/26/2015 3:56:17 PM
KEITH E. HOTTLE
vs. § FOURTH COURT Clerk
THE STATE OF TEXAS, § SAN ANTONIO, TEXAS
Appellee
MOTION FOR EXTENSION OF
TIME TO FILE APPELLANT’S BRFIEF
TO THE HONORABLE COURT OF APPEALS:
Now comes, Alvin Valadez, Jr., appellant in the instant cause, by and
through his undersigned counsel, Edward F. Shaughnessy, and files this
Appellant’s Motion for Extension of Time to File Appellant’s Brief. In
support of the instant motion the Appellant would show unto this Court the
following:
A.
The Appellant is appealing the judgment of the 25th District Court of
Guadalupe County Texas wherein he was convicted, following a jury trial,
of the offense of Possession of a Controlled Substance. The Appellant was
sentenced to Life in confinement in the Institutional Division of the Texas
Department of Criminal Justice. Notice of Appeal was filed in a timely
fashion in the trial Court.
B.
The undersigned was retained to represent the appellant in the instant
matter. The record from the trial Court has been timely submitted to this
Court. This is the appellant’s second request for an extension of time to file
the appellant’s brief. The appellant’s brief was due to be filed in this Court
on January 21, 2015.
C
The undersigned has recently had a water pipe burst at his home
therefore requiring him to spend a great deal of time out of the office dealing
with insurance adjusters and contractors in order to remedy the issues
relating to the water damage to his home.
D.
The appellant respectfully requests an extension of time of thirty days
until February 20, 2015 in which to file the appellant’s brief.
E.
The undersigned has recently filed briefs in the following matters:
Ruben Andres Baldez v. The State of Texas, Cause No. 13-14-00257-CR;
Israel Ytuarte Rodriguez v. The State of Texas, Cause No. PD-0278-14;
Dustin Charles Wilmer v. The State of Texas, Cause No. 07-14-00266-CR.
E.
The undersigned is also in the process of compiling a brief on behalf
of the appellee in the case of Edgar Javier Gonzales v. The State of Texas,
Cause No. 04-14-00100-CR. Moreover the undersigned is in the process of
filing briefs on behalf of the appellant in the case of Jeffrey Lee v. The State
of Texas 04-14-00256-CR. Lastly, the undersigned is in the process of filing
a Petition for Discretionary Review on behalf of the appellant in the case of
James Garza v. The State of Texas, Cause No. PD-0045-15.
F.
In addition the undersigned serves as a part-time Criminal law
Magistrate for the District Courts of Bexar County and as a Juvenile Referee
for the Juvenile Courts of Bexar County. Counsel will be serving in those
capacities during the upcoming days.
PRAYER FOR RELIEF
Wherefore premises considered, the Appellant would request a thirty
day extension of time file the brief in the instant case until February 20,
2015.
Respectfully submitted,
/S/ Edward F. Shaughnessy
Edward F. Shaughnessy, III
Attorney for the Appellant
206 East Locust Street
San Antonio, Texas 78212
SBN: 18134500
Phone: (210) 212-6700
Fax: (210) 212-2178
Shaughnessy727@gmail.com
CERTIFICATE OF SERVICE
I, Edward F. Shaughnessy, hereby certify that a copy of the instant
motion was served upon Heather McMinn, attorney for the appellee, by
mailing the motion to 211 W. Court, Suite 260, Seguin, Texas 78115, on the
_26_ day of February, 2015.
/S/ Edward F. Shaughnessy
Edward F. Shaughnessy, III
Attorney for the Appellant