ACCEPTED
04-14-00709-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
4/23/2015 11:10:54 AM
KEITH HOTTLE
CLERK
Nos. 04-14-00709-CR
STATE OF TEXAS § IN THE COURT OF APPEALS
FILED IN
4th COURT OF APPEALS
VS. § SAN ANTONIO,
FOURTH JUDICIAL TEXAS
DISTRICT
4/23/2015 11:10:54 AM
FRANCISCO JAVIER GONZALEZ § BEXAR COUNTY, TEXAS
KEITH E. HOTTLE
Clerk
FOURTH MOTION FOR EXTENSION OF TIME
TO FILE OPENING BRIEF
From the 399th District Court of Bexar County, Texas
Trial Court No. 2011-CR-9697
Hon. Ray J. Olivarri, Judge Presiding
In accordance with Tex. R. App. P. 10.5(b), the undersigned submits the following:
Appellant’s brief is due to be filed on Monday, the 27th of April, 2015. The undersigned
requests additional time to prepare and file Appellant’s opening brief. Counsel is set for jury
trial on Monday, April 27th, in Williamson County, in Cause Number 14-04880-3, State of Texas
vs. Juan Vasquez Galarza. Counsel has been preparing for trial in the event the Court chooses to
proceed in this cause. As a result, Counsel has been unable to finish Appellant’s brief. While this
is counsel’s fourth request for an extension, the previous requests were due mostly to awaiting
the trial court’s written findings of fact. Counsel requests an extension of seven (7) days, to and
including Monday, May 4, 2015. This is Appellant’s fourth request for an extension.
Counsel has spoken with Ms. Laura Durbin, attorney with the Bexar County District
Attorney’s Office Appellate Section, and she has indicated that she is NOT OPPOSED to
Appellant’s request.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this
Court grant the requested extension.
Respectfully submitted,
Robert A. Jimenez
De Mott, McChesney, Curtright & Armendariz, LLC.
800 Dolorosa Street, Suite 100
San Antonio, Texas 78207
210/354-1844
210/212-2116 - fax
By: /s/ Robert A. Jimenez
SBN: 24059125
CERTIFICATE OF SERVICE
I hereby certify that on this the 23rd day of April, 2015 a copy of the foregoing “Motion
for Extension of Time to File Appellant’s Opening Brief” has been electronically filed with this
Court, and will be served to the Bexar County District Attorney’s Office on April 23, 2015.
/s/ ROBERT A. JIMENEZ