Juan Reyes, Jr. v. State

ACCEPTED 01-15-00178-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 7/9/2015 3:05:16 PM CHRISTOPHER PRINE CLERK NO. 01-15-00178-CR FILED IN 1st COURT OF APPEALS IN THE COURT OF APPEALS FOR HOUSTON, TEXAS THE FIRST DISTRICT OF TEXAS 7/9/2015 3:05:16 PM AT HOUSTON CHRISTOPHER A. PRINE Clerk JUAN REYES, Appel/ant, v. THE STATE OF TEXAS, Appel/ee. Appealed from the 184th District Court of Harris County, Texas Trial Court Cause Number 1313736 MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT Joseph Salhab State Bar #17532300 2028 Buffalo Terrace Houston, Texas 77019 Tel. (713) 528-1005 Fax: (713) 528-2424 josephsalhab@mindspring.com COUNSEL FOR APPELLANT JUAN REYES NO. 01-15-00178-CR IN THE COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS AT HOUSTON JUAN REYES, Appellant, v. THE STATE OF TEXAS, Appellee. Appealed from the 184th District Court of Harris County, Texas Trial Court Cause Number 1313736 MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, JUAN REYES, Appellant, by and through his attorney of record on appeal, Joseph Salhab, files this Motion for Extension of Time to File Appellant's Brief. In support of said Motion, the Appellant shows the Court the following: I. The Appellant was convicted in the 184th District Court of Harris County, Texas, on or about February 12, 2015 in Cause Number 1313736, of Capital Murder and sentenced to life imprisonment without the possibility of parole. Appellant gave timely notice of appeal. II. Appellant's brief was originally due on July 9, 2015. This is Appellant's first Motion for Extension. III. Appellant is requesting the Court grant an extension of forty-five (45) days for filing the Appellant's Brief until August 23, 2015. IV. Appellant's request for an extension of time is based on the fact that he is engaged in numerous other trial and appellate cases. Significant cases include: The State of Texas v. Marquisha A. Williams, in the 248th District Court of Harris County, Texas. Defendant is charged with Capital Murder. The case was set for May 26, 2015. The State of Texas v. Ricky Gaines, in the 184th District Court of Harris County, Texas. Defendant is charged with Aggravated Assault. The case is set for July 14, 2015. The State of Texas v. Byron Chatman, in the 184th District Court, Harris County, Texas. Defendant is charged with Burglary of a Habitation. The case is set for July 14, 2015. The State of Texas v. Ronald Haskell, in the 248 th District Court of Harris County, Texas. Defendant is charged with Capital Murder. The case was set April 22, 2015. Change of venue hearing was set for June 24, 2015. The State of Texas v. Wilbert Lewis, in the 183rd District Court of Harris County, Texas. Defendant is charged with Aggravated Robbery. The case is set for jury trial July 15, 2015. The State of Texas v. Merrick West, in the 338 th District Court of Harris County, Texas. Defendant was charged with Aggravated Robbery. The case is set for July 23,2015. James Rivera v. The State Of Texas, in the 14th Court of Appeals of Houston, Texas. Appellant brief was filed May 8, 2015. Ralph Garcia, Jr. v. The State of Texas, in the 1st Court of Appeals of Galveston, Texas. Appellant brief was filed June 24, 2015. Additionally, Appellant's attorney is involved in numerous other trial and appellate cases, not listed here. WHEREFORE, PREMISES CONSIDERED, Appellant prays that the Court grant an extension of forty-five (45) days, until August 23, 2015, to file Appellant's Brief. Respectfully submitted, ~c~ JSaitlab ------- State Bar #17532300 2028 Buffalo Terrace Houston, Texas 77019 Tel. (713) 528-1005 Fax: (713) 528-2424 josephsalhab@mindspring.com COUNSEL FOR THE APPELLANT JUAN REYES CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing motion +- was delivered to Assistant District Attorney for Har~, Texas, via notice of electronic filing (NEF), on the day of c= ,2015. ~4~ JOALHAB '- VERIFICATION STATE OF TEXAS § § COUNTY OF HARRIS § BEFORE ME, the undersigned authority on this day personally appeared JOSEPH SALHAB, who being duly sworn has deposed and stated upon oath: "My name is JOSEPH SALHAB. I am the Appel/ant's attorney on appeal in the above-styled and numbered cause. I have read the above and foregoing Motion to Extend Time to file Appel/ant's Brief and the facts contained therein are true and correct." SUBSCRIBED AND SWORN TO BEFORE ME, the undersigned authority, on this the 7'fJ. day of -:::Tu-fj , 2015, to certify which, witness my hand and official seal of office. .. S*ill:?P.RYlEE APPLEWHITE \'1" M'i COMMiSSION EXPIRES .;'.:' ~'/;-l' M'A_J.18 2017 ... ..'·· .. - ...,.-_ ';~'l: ...·i ..::,.~ ··h~ idlVlI,