PD-0143-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/9/2015 12:45:23 PM
June 9, 2015
Accepted 6/9/2015 1:09:12 PM
ABEL ACOSTA
CLERK
Cause No. PD-0143-15
COURT OF CRIMINAL APPEALS
OF TEXAS
CYNTHIA AMRBOSE, §
Appellee/Petitioner, §
§ FROM THE
FOURTH COURT OF
vs. §
APPEALS
§ SAN ANTONIO, TEXAS
THE STATE OF TEXAS, § 04-13-00788-CR
Appellant/Respondent. §
UNOPPOSED FIRST MOTION FOR
EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUDGES OF THE COURT OF CRIMINAL APPEALS:
NOW COMES Petitioner, CYNTHIA AMBROSE, by and through her
undersigned counsel, and files this Unopposed First Motion for Extension of Time
to file his Brief, pursuant to Rules 38.6(d) of the Texas Rules of Appellate Procedure.
Appellant respectfully requests a forty (35) day extension to and including July 24,
2015. This is Petitioner’s first motion for extension of time to file her brief. In
support of this motion Petitioner would show as follows:
1. Petitioner’s brief is currently due on June 19, 2015.
2. Counsel has conferred with S. Patrick Ballantyne, Bexar County Assistant
District Attorney, and he does not oppose this motion.
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3. Undersigned counsel was out of the office for her wedding and honeymoon
from May 20, 2015 (the day discretionary review was granted) until June 1,
2015.
4. Undersigned counsel has been working on a Reply Brief in Martinez v. State,
cause number 04-14-00619-CR in the Fourth Court of Appeals.
5. Undersigned counsel also has a brief due on June 25, 2015 in Gonzales v.
State, cause number 04-14-00649-CR in the Fourth Court of Appeals.
6. Undersigned counsel was also preparing for trial in State v. Steen that was set
for June 8, 2015, and was dismissed on the day of trial.
7. Undersigned counsel was also ordered to respond to pretrial motions filed by
the State in State v. Cordero which the response was filed on June5, 2015 in
the 437th.
8. Undersigned counsel is also set for a Motion to Suppress hearing in State v.
Schwartz, 2015-CR- on June 15, 2015 in the 226th District Court.
PRAYER FOR RELIEF
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully prays
that this Honorable Court grant her an additional forty (35) days to and including
July 24, 2015 to file her brief and for any other relief under this Court’s supervisory
power.
Respectfully submitted:
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___/s/ Dayna L. Jones______
DAYNA L. JONES
Bar No. 24049450
LAW OFFICE OF DAYNA L. JONES
1800 McCullough
San Antonio, Texas 78212
(210) 255-8525 office
(210) 223-3248 facsimile
Attorney for Petitioner,
CYNTHIA AMBROSE
CERTIFICATE OF SERVICE
I hereby certify that a copy of the above foregoing Unopposed Motion for
Extension of Time to File Brief has been served via e-mail through the EFSP
Electronic Filing System, to S. Patrick Ballantyne, Assistant Criminal District
Attorney, sballantyne@bexar.org, on this the 9th day of June, 2015.
By: ___/s/ Dayna L. Jones______
DAYNA L. JONES
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