ACCEPTED
04-14-00338-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
9/29/2015 2:54:45 PM
KEITH HOTTLE
CLERK
NO.
04-‐14-‐00338-‐CR
FILED IN
4th COURT OF APPEALS
BENNY
CAVASOS
VALVERDE,
§
IN
THE
COURT
OF
TEXAS
SAN ANTONIO,
Appellant
09/29/15 2:54:45 PM
KEITH E. HOTTLE
Clerk
vs.
§
APPEALS,
FOURTH
THE
STATE
OF
TEXAS,
§
COURT
OF
APPEALS
Appellee
§
SAN
ANTONIO,
TEXAS
A
MOTION
FOR
EXTENSION
OF
TIME
TO
FILE
APPELLEE’S
BRFIEF
TO
THE
HONORABLE
COURT
OF
APPEALS:
Now
comes
the
State
of
Texas,
Appellee
in
the
instant
cause,
by
and
through
his
undersigned
counsel,
Edward
F.
Shaughnessy,
and
files
this
Appellee’s
Motion
for
Extension
of
Time
to
File
Appellee’s
Brief.
In
support
of
the
instant
motion
the
Appellee
would
show
unto
this
Court
the
following:
A.
The
Appellant
is
appealing
the
judgment
of
the
290th
District
Court
of
Bexar
County
Texas
wherein
he
was
convicted
of
Murder
and
sentenced
to
thirty
(30)
years
of
confinement
in
the
Institutional
Division
of
the
Texas
Department
of
Criminal
Justice.
Notice
of
Appeal
was
filed
in
a
timely
fashion
in
the
trial
Court.
B.
The
undersigned
is
serving
as
a
prosecutor
pro
tem
pursuant
to
an
appointment
by
the
judge
of
the
290th
District
Court
of
Bexar
County
due
to
a
conflict
of
interest
on
the
part
of
the
Criminal
District
Attorney
for
Bexar
County.
The
undersigned
did
not
serve
as
the
prosecutor
in
the
trial
Court.
C.
The
Appellant’s
brief
in
the
instant
matter
was
filed
in
this
Court
on
June
1,
2015.
The
Appellee’s
brief
was
due
to
be
filed
on
September
21,
2015.
The
Appellee
would
request
a
thirty-‐day
extension
of
time
to
file
the
Appellee’s
brief
until
October
21,
2015.
C.
Counsel
is
in
the
process
of
compiling
briefs
in
the
following
matters:
James
Garza
v.
The
State
of
Texas,
Cause
No.
04-‐15-‐000456-‐CR
and
Richard
Longoria
v.
The
State
of
Texas,
Cause
No.
13-‐15-‐00173-‐CR.
The
undersigned
is
also
in
the
process
of
compiling
a
Petition
for
Discretionary
Review
in
the
case
of
Alvin
Valadez
v.
The
State
of
Texas,
Cause
No.
04-‐1400626-‐CR.
D.
The
record
of
the
instant
case
has
been
obtained
from
the
office
of
the
Clerk
and
a
review
of
that
record
has
been
undertaken.
E.
The
undersigned
is
also
in
the
process
of
compiling
a
proposed
order
on
the
post-‐conviction
writ
of
habeas
corpus
in
the
case
of
Ex
Parte
Denise
Crouch,
Cause
no.
08-‐06-‐9897-‐1-‐CR,
currently
pending
before
the
38th
District
Court
for
Medina
County.
PRAYER
Wherefore
premises
considered,
the
Appellee
would
request
a
sixty
day
extension
of
time
file
the
brief
in
the
instant
case
until
October
21,
2015.
Respectfully
submitted,
/S/_____________________________
Edward
F.
Shaughnessy,
III
Attorney
for
the
Appellee
206
East
Locust
Street
San
Antonio,
Texas
78212
SBN:
18134500
Phone:
(210)
212-‐6700
Fax:
(210)
212-‐2178
Shaughnessy727@gmail.com
CERTIFICATE
OF
SERVICE
I
hereby
certify
that
a
copy
of
the
instant
motion
was
served
upon
David
Schulman,
attorney
for
the
appellant
by
e-‐mailing
the
motion
to
zdrdavida@davidschulman.com
on
this
the
29th
day
of
September,
2015.
/S/____________________________
Edward
F.
Shaughnessy,
III
Attorney
for
the
Appellant