A-77,042
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/7/2015 7:36:00 PM
Accepted 12/8/2015 7:50:25 AM
ABEL ACOSTA
TEXAS COURT OF CRIMINAL APPEALS CLERK
AUSTIN, TEXAS
FIDENCIO VALDEZ )
)
V. ) A-77,042 December 8, 2015
)
THE STATE OF TEXAS )
M OTION FOR EXTENSION OF TIM E TO FILE APPELLANT’S BRIEF
TO THE HONORABLE COURT OF CRIM INAL APPEALS:
Fidencio V aldez, Appellant in this cause, moves the Court for an extension of time
for filing Appellant’s brief, and in support of this motion show:
I.
This is an appeal from the 384th Judicial District Court for the State of Texas.
II.
The Appellant’s brief is due today December 7, 2015. Undersigned counsel, who is
entering an appearance as co-counsel for Appellant, believes this is the third extension of
time for filing the Appellant’s brief.
III.
To-date, undersigned counsel has expended innumerable hours reading the reporter’s
record of the trial and conducting legal research into various issues of the case. The
reporter’s record of the trial is massive and the issues which needed to be researched
complex. U ndersigned counsel has also conferred with Joe Vasquez, lead counsel on the
case, who has related to undersigned counsel to file this motion for continuance and request
an additional 90 day to prepare Appellant’s brief. Undersigned counsel and lead counsel, Joe
Vasquez, accordingly request an additional 90 days to prepare and submit Appellant’s brief.
IV.
Respectfully submitted,
/s/ Jam es D . Lucas
JAM ES D. LUCAS
2316 M ontana Avenue
El Paso, TX 79903
(915) 532-8811
(915) 532-8807
State Bar No. 12658300
C E R T IFIC A TE O F SE R V IC E
This is to certify that on December 7, 2015 a true and correct copy of the above and
foregoing document was served by mail, District Attorney’s Office, 500 E. San Antonio, El
Paso, Texas 79901.
/s/ Jam es D . Lucas
JAM ES D. LUCAS