ACCEPTED
03-15-00439-CR
8152203
THIRD COURT OF APPEALS
AUSTIN, TEXAS
12/9/2015 10:05:26 AM
JEFFREY D. KYLE
CLERK
CAUSE NO. 03-15-00439-CR
JOHN GABRIEL ESQUIVEL § IN THE THIRD COURT
Appellant, § FILED IN
3rd COURT OF APPEALS
§ AUSTIN, TEXAS
§ 12/9/2015 10:05:26 AM
v. § OF APPEALS
JEFFREY D. KYLE
§ Clerk
THE STATE OF TEXAS §
Appellee, § STATE OF TEXAS
SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES JOHN ESQUIVEL, Appellant, by and through their attorney, Amber
Vazquez Bode, and file this Second Motion for Extension of Time to File Appellant's Brief.
In support thereof Appellant offers as follows:
1. According to the Texas Rules of Appellate Procedure Rule 38.6 Time to File
Briefs:
"(a) Appellant's Filing Date. Except in a habeas corpus or bail appeal, which is
governed by Rule 31, an appellant must file a brief within 30 days-20 days in an accelerated
appeal-after the later of:
( 1) The date the clerk's record was filed; or
(2) The date the reporter's record was filed."
2. The Reporter's Record was filed on October 8, 2015.
3. The appellant's brief is due on December 9, 2015.
4. The Appellant cites the following facts and reasons to the Court as Justification
for this Second Motion for Extension:
a) Counsel just got out of a felony trial on December 3, 2015 in the 368th District
Court in Williamson County Texas, Cause No. 14-1915-K368. Furthermore counsel
is needing an extension to gather research and was unable to gather all research due to '
the felony trial last week.
5. Appellant hereby requests an extension of 30 days due to the stated reasons.
6. Appellant respectfully requests a brief extension of 30 days in order to receive
proper research for the case.
The Appellant respectfully requests that this court GRANT the Second Motion for
Extension of Time to File Appellant's Brief.
R
A azquez Bode
State Bar No. 24039225
The Vazquez Law Firm
1004 West Ave.
Austin, Texas 78701
(512) 220-8507 (telephone)
(512) 480-0760 (facsimile)
COUNSEL FOR APPELLANT
CERTIFICATE OF SERVICE
I, AMBER VAZQUEZ BODE, Attorney for Appellant, do hereby certify that a true and
correct copy of the above and foregoing Second Motion for Extension of Time to File
Appellant's Brief has been served electronically on
Third Court of Appeals
Price Daniel Sr. Bldg.
209 West 14th Street, Room 101
Austin, Texas 78701
Ms. Angela Chambers
299th District Court
Official Court Reporter
299th Judicial District Court
Blackwell-Thurman Justice Center
509 West 11th Street- 8th Floor
Austin, Texas 78701
Travis County District Attorney
Appellate Division
509 West 11th Street
Austin, Texas 78701
Travis Count~ District Clerk
509 West 11 t Street, Room 1.400
Austin, Texas 78701
The Honorable Karen Sage
299th District Court
Blackwell-Thurman Justice Center
509 West 11th Street- 8th Floor
Austin, Texas 78701
John Gabriel Esquivel v. State
Combined Opinion