Luis Ruiz Sierra v. State

ACCEPTED 01-14-00493-CR FIRST COURT OF APPEALS HOUSTON, TEXAS 10/12/2015 12:00:00 AM CHRISTOPHER PRINE CLERK NO. 01-14-00493-CR FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 10/10/2015 4:18:24 PM CHRISTOPHER A. PRINE Clerk IN THE COURT OF APPEALS OF TEXAS FIRST SUPREME JUDICIAL DISTRICT LUIS RUIZ SIERRA, APPELLANT VS. STATE OF TEXAS, APPELLEE MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE APPELLANT’S BRIEF TERRENCE GAISER LAWYER FOR APPELLANT 2900 SMITH STREET, # 220 HOUSTON, TEXAS 77006 SBOT# 07572500 713/ 225-0666 tagaiser@aol.com NO. 1396147 STATE OF TEXAS § IN THE DISTRICT COURT § VS. § HARRIS COUNTY,TEXAS § LUIS RUIZ SIERRA § 182ND JUDICIAL DISTRICT MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE APPELLANT’S BRIEF NOW COMES LUIS RUIZ SIERRA, appellant in the above- captioned cause, by and through his attorney, TERRENCE GAISER, and files his Motion for Extension of time within which to file Appellant’s Brief; for which he would show: 1) This is an appeal from a conviction for the offense of burglary of a habitation with the intent to commit the felony of sexual assault. Punishment was assessed at thirty years confinement. Notice of appeal and the certification of appellant’s right to appeal were timely filed. 2) This is the second requested extension of time. The brief was due September 28, 2015. 3) Appellant would request an extension of time to file the brief to and including the 30th day of October, 2015. 4) For good cause counsel for the appellant would show that he has not had time to complete the brief in this cause for the following reasons: 1 a) For the past three weeks counsel has been preparing for the death penalty trial in the case of State of Texas v. William Michael Mason, Cause Number 0620074, in the 228th District Court, scheduled to begin Monday, October 12, 2015. b) Counsel has been in the criminal courts of the State of Texas in Harris County, Texas, and surrounding counties on a daily basis since the inception of this appeal as follows: 09/02/15 263rd District Court State v. Morris Agg.Robb 09/03/15 174th District Court State v. Perez Burg.Hab. 09/03/15 174th District Court State v. Moore Burg.Hab. 09/08/15 351st District Court State v. Robinson PCS 09/08/15 351st District Court State v. Casiano Agg. Asslt. 09/09/15 263rd District Court State v. Morris Agg. Robb. 09/10/15 263rd District Court State v. Lyons Agg. Robb. 09/11/15 351st District Court State v. Casiano Agg. Asslt. 09/11/15 174th District Court State v. Perez DWI 09/14/15 351st District Court State v. Casiano Agg. Asslt. 09/14/15 351st District Court State v. Haywood Agg.Sx.Asslt. 09/16/15 262nd District Court State v. Garcia Agg.Asslt. 09/17/15 174th District Court State v. Stevens Burg.Hab. 2 09/17/15 174th District Court State v. Scott Agg.Asslt. 09/17/15 174th District Court State v. Rodriguez Theft 09/17/15 179th District Court State v. Omarmustafa Agg.Asslt. 09/18/15 179th District Court State v. Aleman PCS 09/18/15 185th District Court State v. Denkins Cap. Murder 09/22/15 232nd District Court State v. Nixon Agg. Robb. 09/22/15 232nd District Court State v. Muscovalley Evading 09/23/15 228th District Court State v. Amaya Tampering 09/23/15 178th District Court State v. Banks Robbery 09/24/15 184th District Court State v. Boyd Agg. Robb. 09/24/15 228th District Court State v. Mason Cap. Murder 09/25/15 177th District Court State v. Jacobs Sx.Assslt.Ch 09/25/15 185th District Court State v. Denkins Cap.Murder 09/29/15 176th District Court State v. Cooper Eng.Org.Crm 09/29/15 174th District Court State v. Moore Agg.Asslt. 09/30/15 339th District Court State v. Tornes IDFraud 09/30/15 351st District Court State v. Batts Agg.Asslt. 09/30/15 262nd District Court State v. Garcia Agg.Asslt. 10/01/15 178th District Court State v. Rodriguez Cap.Murder 10/01/15 179th District Court State v. Nagel PCS 3 10/01/15 182nd District Court State v. Murdie PCS 10/01/15 174th District Court State v. Scott Agg.Asslt 10/02/15 174th District Court State v. Drayton Cap.Murder 10/05/15 174th District Court State v. Scott Agg.Asslt. 10/08/15 351st District Court State v. Robinson PCS 10/08/15 174th District Court State v. Rodriguez DWI 10/09/15 177th District Court State v. Azzeh Burg.Hab. Counsel has had other cases in other counties not included in this list. c) Counsel has other briefs due in this Court and the 14th Court that he is trying to complete. WHEREFORE, PREMISES CONSIDERED, Appellant prays for an extension of time to file the Appellant’s Brief to and including Ocktober 30, 2015. RESPECTFULLY SUBMITTED, S/Terrence A. Gaiser TERRENCE A. GAISER LAWYER FOR APPELLANT 2900 SMITH STREET, # 220 HOUSTON, TEXAS 77006 SBOT# 07572500 tagaiser@aol.com CERTIFICATE OF SERVICE 4 I CERTIFY THAT A COPY OF THE ABOVE AND FOREGOING MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE APPELLANT’S BRIEF WAS SERVED ON ALL PARTIES ACCORDING TO THE RULES. S/Terrence A. Gaiser TERRENCE A. GAISER 5