Barry Pizzo v. State

ACCEPTED 03-14-00701-CR 5574937 THIRD COURT OF APPEALS AUSTIN, TEXAS 6/8/2015 10:22:57 AM JEFFREY D. KYLE CLERK NO. 03-14-00701-CR FILED IN 3rd COURT OF APPEALS STATE OF TEXAS § INTHE AUSTIN, TEXAS § 6/8/2015 10:22:57 AM vs. § THIRD COURT JEFFREY D. KYLE § Clerk BARRY PIZZO § OF APPEALS SECOND MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF TO THE HONORABLE JUSTICES OF SAID COURT: Now comes Barry Pizzo, Appellant in the above styled and numbered cause, and moves this Court to grant an extension of time to file appellant's brief, pursuant to Rule 38.6 of the Texas Rules of Appellate Procedure, and for good cause shows the following: 1. This case is on appeal from the 207th Judicial District Court of Comal County, Texas. 2. The case below was styled the STATE OF TEXAS vs. Barry Pizzo, and numbered CR2013-146. 3. Appellant was convicted of Two Counts of Tampering with Evidence. 4. Appellant was assessed a sentence of life in prison on 7th day of October, 2014. 5. Notice of appeal was given on November 4, 2014. 6. The clerk's record was filed on February 2, 2015; the reporter's record was filed on March 11, 2015. 7. The appellate brief is presently due on June 9, 2015. 8. Appellant requests an extension of time of 60 days from the present date, i.e. August 8, 2015. 9. One extension to file the brief has been received in this cause. 10. Defendant is currently incarcerated. 11. Appellant relies on the following facts as good cause for the requested extension: Counsel, after communicating with Defendant, believes that Mr. Pizzo's interested will be best served by having new counsel appointed for his appeal. Counsel has filed a Motion to Withdraw with the trial court, requesting new counsel be appointed. WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant this Motion To Extend Time to File Appellant's Brief, and for such other and further relief as the Court may deem appropriate. Respectfully submitted, ATANACIO CAMPOS P.O. Box 310859 New Braunfels, TX 78131 Tel: (830) 620-1515 Fax: (830) 620-5334 By: ~~~~~~~~-------­ Atana ·o Campos State Bar No. 03720700 atanacio@aol.com Attorney for Barry Pizzo CERTIFICATE OF SERVICE This is to certify that on June 5, 2015, a true and correct copy of the above and foregoing document was served on the District Attorney's Office, Comal County, 150 N. Seguin Ave., New Braunfels, Texas, by electronic service through the Electronic Filing Manager. STATE OF TEXAS § § COUNTY OF COMAL § AFFIDAVIT BEFORE ME, the undersigned authority, on this day personally appeared Atanacio Campos, who after being duly sworn stated: "I am the attorney for the appellant in the above numbered and entitled cause. I have read the foregoing Motion To Extend Time to File Appellant's Brief and swear that all of the allegations of fact contained therein are true and correct." SUBSCRIBED AND SWORN TO BEFORE ME on June 5, 2015, to certify which witness my hand and seal of office. Notary Public, State of Texas 06/08/2015 07:33 FAX 8306082030 COMAL-OISTRICT-COURT Ill 004/007 STATE OF TEXAS NO. 03-14-00701-CR § IN THE DISTRICT COURT ~;.~ ~ w"U -< e11 ~ - ( ,71 .... ,.. c.... ~~ p~ ::z: c::= ..,., r- M 0 § ,.,,., '"1"1 vs. § 2.07th JUDICIAL DISTRICT ~:0 r,?! ' U'\ 0 :::0 § o:=oo; :J:f"l'1 ):loot ::::1: ::tJ BARRY PIZZO § COMAL COUNTY, TEXAS >!= ~"""'> n::;g .. C5 rr1 n 0 ORDER ON MOTION TO WJTIIDRAWAS COUNSEL ;.... -< = Q ~ 0 On~{.ame on to be considered Atanacio Campos's Motion to Withdraw as Counself . The Court fmds that there is good cause for withdrawal of Movant as counsel and such withdrawal is not sought only for delay. The pending settings and deadlines in the case are as follows: a. Appellant's Briefis due to the Thrid Court of Appeals on June 9. 2015. The Court finds that Barry Pizzo, Defendant, is indigen~ and is entitled to the appointment of counsel to represent said Defendant on appeal. The Court further fm.ds that Movant has timely filed a notice of appeal, requested the Clerk's Record and the Reporter's Record, and said records have been produced and tiled.. IT IS THEREFORE ORDERED, that Movant is pennitted to withdraw as counsel of record for Barry Pizzo in this cause. The Court hereby appoints ~---------- as counsel of record for Barry Pizzo herein. Identifying information for new counsel is as follows: State Bar Number: Address: Telephone Number: Fax Number: The Court ORDERS that Atanacio Campos, Movant, immediately provide written 06/08/2015 07:33 FAX 8306082030 COMAL-DISTRICT-COURT Ill 003/007 NO. 03-14.00701-CR STATE OF TEXAS § IN THE DISTRICT COURT § va. § 207th JUDICIAL DISTRICT § BARRY PIZZO § COMAL COUNTY, TEXAS NQTICI To: Barry Piz%o NOTICE is hereby given, as provided by Rule 6 of the Texas Rules of Appellate Procedme, that the following deadlines and/or settings exist in this case: a. Appellant's Brief is due to the Tbrid Court of Appeals on June 9, 2015. b. A Motion for Extension ofTime t0 File Appellant's Brief has been filed. Law Office of Atanacio Campos P.O. Box 310859 496 S. Castell Ave. New Braunfels, Texas 78131-0859 Tel: (830) 620-1515 Fax: (830) 620-5334 By:.~~~--~~~~~--~---­ Atanac.t»"'\.:aaees- State Bar No. 03720700 atanacio@aol.com Attorney for Barry Pizzo I certify that a copy of this Notice has been mailed by certified mail and by regular mail to the above-named Defendant at his last known address: IDCJ# 01967172, 9601 Spur 591, Amarillo, Texas 79107 on June 5, 2015. 06/08/2015 07 : 33 FAX 8306082030 COMAL-OISTRICT-COURT ~ 002/007 PRAYER WHEREFORE, PREMISES CONSIDERED, Movant prays thllt the Court allow Atanacio Campos to withdraw as counsel for Barry Pizzo and from any further representation of Barry Pizzo in this cause. Defendant and Movant further pray the Court appoint counsel to represent Defendant in the appeal of this case. Respectfully submitted, Law Office of Atanacio Campos P.O. Box 310859 496 S. Castell Ave. New Braunfels, Texas 78131-0859 Tel: (830) 620·1515 Fax: (830) 620-5334 By: ·AA~aM~ciWo~mmrw~~~~~~-- state Bar No. 03 720700 atanacio@aol.com Attorney for Barry Pizzo CERTIFICATE OF SERVICE This is to certify that on JW1e S, 201S, a true and correct copy of the above and foregoing docwnent was served on the District Attorney's Office, Comal CoWlty, 150 N. Seguin Ave., New Braunfels, Texas 78130, by facsimile transmission to (830) 608-2008.