ACCEPTED
04-15-00640-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
12/22/2015 5:13:36 PM
KEITH HOTTLE
CLERK
CAUSE NO. 04-15-00640-CR
EDUARDO REYES, § IN THE COURT OF APPEALS
FILED IN
4th COURT OF APPEALS
Appellant § SAN ANTONIO, TEXAS
VS. § IN SAN ANTONIO, TEXAS
12/22/15 5:13:36 PM
§ KEITH E. HOTTLE
THE STATE OF TEXAS, §
th
Clerk
4 JUDICIAL DISTRICT
Appellee
MOTION FOR EXTENSIONOF TIME TO FILE APPELLANT'S BRIEF
TO THE HONORABLE JUDGES OF SAID COURT:
COMES NOW, EDUARDO REYES, Appellant, and files this Motion for
Extension of Time to File Appellant's Brief, pursuant to Rules 10.5(b) and 38.6(d),
Texas Rules of Appellate Procedure. In support of this Motion, Appellant would
show the following:
I.
Appellant’s brief is due to be filed on December 21, 2015. Counsel for
Appellant requires an extension of thirty (30) days within which to complete and file
Appellant’s brief in this cause. This is Appellant’s first request for extension of
time.
II.
Counsel for Appellant has worked diligently on the brief since receiving
the record, but has been unable to complete it for the following reasons:
1. Counsel for Appellant had numerous, previously set, pretrial and trial
settings in the county and district criminal courts of Bexar County, Texas, and in
the United States District Court, Western District of Texas — San Antonio
Division.
III.
This request is not made for the purpose of delay, but rather this request is
made to allow counsel adequate time to prepare Appellant’s Brief. Appellant
moves this Court for an order granting an extension of thirty (30) days, or until
January 21, 2016, for Appellant to submit the brief in this case.
WHEREFORE, PREMISES CONSIDERED, Appellant moves this Court
for an order granting an extension of thirty (30) days for Appellant to submit the
brief in this case.
Respectfully submitted,
Robert F. Gebbia
Law Offices of William T. Reece, Jr.
107 Woodward Place
SAN ANTONIO, TX 78204
Tel: (210) 225-7555
Fax: (210) 226-3596
By: /s/
Robert F. Gebbia
State Bar No. 24054162
lawofficewmreece@gmail.com
Attorney for Appellant
CERTIFICATE OF COMPLIANCE
Pursuant to Rule 9 of the Texas Rules Appellate Procedure, the undersigned
counsel of record certifies that the motion contains 503 words.
/s/
Robert F. Gebbia
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing Motion
for Extension of Time to File Appellant's Brief was delivered via email to the Bexar
County District Attorney's Office, Appellate Division, 101 W. Nueva, 4th Floor,
San Antonio, Texas 78205, to: Jeanette.Canales@bexar.org on this the 21st day of
December, 2015.
/s/
Robert F. Gebbia
CAUSE NO. 04-15-00640-CR
EDUARDO REYES, § IN THE COURT OF APPEALS
Appellant §
VS. § IN SAN ANTONIO, TEXAS
§
th
THE STATE OF TEXAS, § 4 JUDICIAL DISTRICT
Appellee
ORDER
On this the _____ day of , 2015 , came on to be heard the
Appellant's Motion for Extension of Time to File Appellant's Brief and the Court is
of the opinion that this Motion should be:
GRANTED, and the deadline for filing the Appellant's brief in Cause No. 04-
15-00640-CR is extended to , 2016.
DENIED, to which action of the Court the Appellant objects.
SIGNED this the day of , 2015.
JUDGE PRESIDING