ACCEPTED
03-14-00602-CR
3905371
THIRD COURT OF APPEALS
AUSTIN, TEXAS
1/26/2015 5:02:43 PM
JEFFREY D. KYLE
CLERK
No. 03-14-00602-CR
In the FILED IN
Court of Appeals 3rd COURT OF APPEALS
AUSTIN, TEXAS
Third District 1/26/2015 5:02:43 PM
Austin, Texas JEFFREY D. KYLE
Clerk
The State of Texas,
Appellant
V.
Anthony James Sanchez,
Appellee
Appeal from the l67th Judicial District Court
Travis County, Texas
Cause Number D- -DC-I 3-200502
l
APPELLEE’S FIRST MOTION FOR EXTENSION OF TIME
TO THE HONORABLE COURT OF APPEALS:
The Appellee, Anthony James Sanchez, by and through the undersigned
counsel Rocio Ramirez, moves for an extension of the deadline for filing the
State’s brief and, in accordance with Texas Rules of Appellate Procedure 38.6 and
l0.5(b), advises the Court as follows:
(a) The appellee filed a Motion to Suppress Evidence on January 27, 2014.
The Trial Court filed an Order granting the Motion to Suppress Evidence on
August 29, 2014. The State of Texas filed a notice of Appeal in the above cause
on September I8, 2014. The reporter’s record was filed on September 30, 2014.
1
The clerk’s record was filed on October I6, 2014. The State filed its brief on
January 5, 2015.
(b) The Appellee’s brief is currently due on January 26, 2015.
(c) This request is that the deadline for filing the Appellee’s brief be
extended by 30 days.
(d) The number of previous extensions of time granted for submission of the
Appellee’s brief is: none.
(e) The Appellee relies upon the following facts to reasonably explain the
need for an extension of deadline:
l. The undersigned counsel is a sole practitioner. The undersigned counsel
has been preparing for a trial which is currently set for February 3, 2015, The State
of Texas v. Benjamin Anguiarzo-Hernandez, Cause No. 431776 and has numerous
pre-trial hearings and immigration matters through January 26, 2015.
2. In addition, this case involves complex issues of fact and law. Counsel
must conduct extensive legal research in order to prepare the Appellee’s brief.
3. This request is not made for the purpose of delay, but to ensure that the
Court has a proper Appellee’s brief to aid in thejust disposition of the above cause.
WHEREFORE, the Appellee respectfully requests that the deadline for
filing the Appellee’s brief be extended to February 26, 2015.
Respectfully submitted,
K
Rocio Ramirez
SBN: 24037328
I603 Babcock, Suite I59
San Antonio, Texas 78229
(210) 785-0443
Fax: (210) 785-0453
Email: rocio@rocioramirezlaw.com
Certificate of Compliance and Service
I hereby certify that this brief contains 485 words, based upon the computer
program used to generate this brief and excluding words contained in those parts of
the brief that Texas Rule of Appellate Procedure 9.4(i) exempts from inclusion in
the word count, and that this brief is printed in a conventional, I4-point typeface.
I further certify that, on the 26"‘ day of January, 2015, a true and correct
copy of this brief was served, by U.S. mail, electronic mail, facsimile, or
electronically through the electronic filing manager, to the Appel|ant’s attorneys,
Angie Creasy, Assistant District Attorney, P.O. Box 1748, Austin, Texas 78767,
fax: (512) 854-48 I 0, email:Angie.Creasy@traviscountytx.gov.
Rocio Ramirez