ACCEPTED
01-14-00861-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
2/26/2015 10:35:58 AM
CHRISTOPHER PRINE
CLERK
No. 01-14-00861 –CR
COURT OF APPEALS FILED IN
1st COURT OF APPEALS
FIRST DISTRICT OF TEXAS HOUSTON, TEXAS
2/26/2015 10:35:58 AM
HOUSTON CHRISTOPHER A. PRINE
Clerk
SEGISMUNDO GONZALEZ,
APPELLANT
v.
STATE OF TEXAS,
APPELLEE
APPELLANT’S SECOND MOTION FOR EXTENSION OF TIME
TO FILE THE APPELLATE BRIEF
To the Honorable Justices of Said Court:
Comes now, SEGISMUNDO GONZALEZ, by and through his attorney of
record, Leah M. Borg, and files this “Second Motion for Extension of Time to File
the Appellate Brief” and for good cause would show the following:
1. APPELLANT’S attorney of record has not had sufficient time to complete
and timely file the appellate brief due to the nature of the case against
APPELLANT; the length of the record; and Counsel’s previously scheduled
court appearances and client commitments.
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2. Further, this appeal is taken from a hearing on a Pre-Sentence
Investigation/Report. In an effort to avoid filing an Anders brief, Counsel
has attempted to develop various points of error; most of which, as a result
of research, Counsel has concluded would not be successful, as being
unsupported by the law.
3. Counsel is presently developing a particular point of error, which may be
successful upon appeal. Counsel requires additional time to finalize this
point of error and finalize the appellate brief draft.
4. Counsel believes she will file the appellate brief on or before Monday,
March 2, 2015, but out of an abundance of caution is requesting an extension
of time through Wednesday, March 4, 2015.
Therefore, Counsel requests the extension of time to in order to complete
and file the appellate brief.
Wherefore, premises considered, the APPELLANT requests an extension of
time to file the appellate brief be granted and for such and other relief to which
this Court deems APPELLANT justly entitled.
Respectfully submitted,
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________________________________
Leah M. Borg
Attorney for APPELLANT
874 Yorkchester No. 123
Houston, Texas 77079
Texas Bar No. 02667800
Email: borg579@att.net
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above Motion was
delivered to the District Attorney, Appellate Division:
Alan Curry 1201 Franklin Houston, Texas 77002
On Feb. 26, 2015, in accordance with the Texas Rules of Appellate Procedure
through: the efile system or by mailing through the USPS.
_____________________________
Leah M. Borg
ATTORNEY FOR APPELLANT
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LEAH M. BORG
ATTORNEY AT LAW
874 YORKCHESTER NO. 123
HOUSTON, TEXAS 77079
TEL. & FAX: 713-468-3618
EMAIL: borg579@att.net
Texas Bar No. 02667800
First Court of Appeals
301 Fannin
Houston, Texas 77002-2066
Attn: Christopher Prine
Re: SEGISMUNDO GONZALEZ v. THE STATE OF TEXAS
Appellate Number: 01-14-00861-CR
Trial Court Number: 1388920; 184th District Court of Harris County, Texas
To Christopher Prine, the Clerk of the Court: Feb. 26, 2015
Attached please find for filing the APPELLANT’S “Second Motion for Extension of Time to File the
Appellate Brief.” A copy of this Motion will be provided to the District Attorney’s Office in accordance
with the Rules of Appellate Procedure.
Total number of pages Motion and cover sheet: 4 pp.
Thank you for your attention to this matter.
Leah M. Borg
Attorney for Appellant Segismundo Gonzalez
Texas Bar No. 02667800
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