Sergio Ibarra Jimenez v. State

ACCEPTED 04-15-00580-CR FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 9/17/2015 11:11:20 AM KEITH HOTTLE 04-15-00580-CR CLERK NO. 2013-CR-11598 FILED IN STATE OF TEXAS § IN THE FOURTH COURT 4th COURT OF APPEALS § SAN ANTONIO, TEXAS vs. § Of APPEALS 09/17/15 11:11:20 AM § KEITH E. HOTTLE SERGIO IBARRA JIMENEZ § DISTRICT OF TEXAS Clerk MOTION TO EXTEND TIME TO FILE NOTICE OF APPEAL TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Sergio Ibarra Jimenez, Defendant in the above entitled and numbered cause, and makes this Motion to Extend Time to File Notice of Appeal, and for good cause shows the following: 1. The deadline for filing the Notice of Appeal in this cause was September 10, 2015. 2. Defendant, an inmate confined in a Texas prison, drafted a pro se Notice of Appeal on September 7, 2015. It was received and filed by the District Clerk of the 379th District Court on September 14, 2015. It appears that Defendant timely filed by mail the Notice of Appeal. This motion is filed to protect Defendant’s appellate rights. 3. On August 11, 2015 Defendant was sentenced to 3 years in prison by the Judge of the 379th District Court of Bexar County Texas. The case is styled: The State of Texas v. Sergio Ibarra Jimenez. The case number is 2013-CR-11598.on August 11, 2015. WHEREFORE, PREMISES CONSIDERED, Defendant prays that this Court grant Defendant's Motion to Extend Time to File Notice of Appeal. Respectfully submitted, Mario A. Trevino 315 S. Main San Antonio, Texas 78204 Tel: (210) 226-0026 Fax: (210) 226-8402 By: /s/ Mario A. Trevino State Bar No. 20211250 trevinomtrev@aol.com Attorney for Sergio Ibarra Jimenez CERTIFICATE OF SERVICE This is to certify that on September 17, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Bexar County, Texas, by hand delivery. /s/ Mario A. Trevino