PD-0756-15
PD-0756-15 COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 6/19/2015 3:17:27 PM
Accepted 6/24/2015 9:40:48 AM
No.___________________ ABEL ACOSTA
CLERK
CHARLES LAVOY ARRINGTON § IN THE TEXAS COURT
§ OF CRIMINAL APPEALS
STATE OF TEXAS § AUSTIN, TEXAS
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
PETITION FOR DISCRETIONARY REVIEW
From the 187th District Court of Bexar County, Texas
Trial Court Nos. 2011- CR-1663
Hon. Sharon McRae, Visiting Judge Presiding
In accordance with Tex. R. App. Pro. 68.2, the undersigned counsel submits his
“Unopposed Motion for Extension of Time to File Petition for Discretionary Review,” and
shows as follows:
The Fourth Court of Appeals denied Appellant’s motions for rehearing, and for rehearing
en banc, on May 21, 2015.
In the interim, Counsel has prepared and filed a motion for rehearing, on an affirmance
after remand, in Villarreal v. State, 2015 Tex. App. LEXIS 2758 (Tex. App. San Antonio Mar.
25, 2015), before the Fourth Court of Appeals of Texas, on Tuesday, June 9, 2015, which is
pending before said Court;
Counsel prepared for, and was set for trial in State v. Hernandez, Cause No. 442924, on
Monday, June 15, 2015, in County Court at Law # 9, involving a DWI > .15 BAC charge. In
lieu of proceeding with jury selection, the case was resolved by dismissal, and plea to an
Obstruction of a Highway, that same day;
Counsel filed an amended brief in State of Texas v. Luis Arnaldo Baez, No.
04-14-00374-CR, with the San Antonio, Fourth Court of Appeals, on Tuesday, June 16, 2015;
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June 24, 2015
Counsel has slotted a vacation with his family, beginning Tuesday, June 23, to
Wednesday, July 1, 2015.
Ms. Lauren Scott, Assistant District Attorney in charge of this case has expressed
that he is not opposed to the requested extension, as communicated to the undersigned via
email communication on Friday, June 19th, 2015.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this
Court grant a 30-day extension of time to file his petition for discretionary review, from Monday,
June 22nd, 2015, to, and including Wednesday, July 22nd, 2015.
Respectfully submitted,
Jorge G. Aristotelidis
Tower Life Building
310 South St. Mary’s Street, Suite 1830
San Antonio, Texas 78205
(210) 277-1906
jgaristo67@gmail.com
By: /s/ JORGE G. ARISTOTELIDIS
SBN: 00783557
Attorney for Petitioner
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CERTIFICATE OF SERVICE
I hereby certify that on this the 19th day of June, 2015 a copy of the foregoing
“Unopposed Motion for Extension of Time to File Petition for Discretionary Review” has been
delivered to the Appellate Section of the Bexar County District Attorney’s Office, via electronic
filing.
/s/ JORGE G. ARISTOTELIDIS
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Arrington, Charles
Combined Opinion