ACCEPTED
04-15-00125-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
6/24/2015 8:29:12 AM
KEITH HOTTLE
CLERK
Nos. 04-15-00125-CR
STATE OF TEXAS § IN THE COURT OF APPEALS
FILED IN
4th COURT OF APPEALS
VS. § SAN ANTONIO,
FOURTH JUDICIAL TEXAS
DISTRICT
6/24/2015 8:29:12 AM
HECTOR RAMIREZ GUTIERREZ § BEXAR COUNTY,
KEITHTEXAS
E. HOTTLE
Clerk
SECOND MOTION FOR EXTENSION OF TIME
TO FILE OPENING BRIEF
th
From the 226 District Court of Bexar County, Texas
Trial Court No. 2013-CR-2894-W1
Hon. Kevin O’Connell, 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 29th of June, 2015. The undersigned
requests additional time to prepare and file Appellant’s opening brief. Counsel has been
working on several appellate cases pending in the Fourth Court of Appeals and the Third Court
of Appeals. Further, counsel has been preparing for various trial cases as well as assisting in one
trial case, State of Texas v. Derrick Diab, Cause No. 2014CR1195. Further, counsel is scheduled
to be out of town from June 24, 2015 through June 27, 2015. As a result, Counsel requests more
time to work on Appellant’s brief. Counsel requests an extension of twenty-one (21) days, to and
including Monday, July 20, 2015. This is Appellant’s second request for an extension.
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 24th day of June, 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 June 24, 2015.
/s/ ROBERT A. JIMENEZ