Jorge Zepeda v. State

ACCEPTED 12-15-00055-CR TWELFTH COURT OF APPEALS TYLER, TEXAS 5/8/2015 3:45:45 PM CATHY LUSK CLERK Cause No. 12-15-00055-cR JORGE ZEPEDA $ IN THE COI]RT OF APPEALS $ FILED IN V. $ 12TH DISTRICT12th COURT OF APPEALS COURT TYLER, TEXAS $ STATE OF TEXAS TYLER, TEXAS5/8/2015 3:45:45 PM CATHY S. LUSK Clerk TO THE HONORABLE JUDGES OF SAID COURT: COMES NOW, Appellant, through JEFF SANDERS, Defense Attorney, in the above show the Court as styled and numbered cause and files this Motion and in support thereof would follows: 1. The Appellant's Brief is due on May 11,2015. Appellant's attorney needs 30 additional days to file the brief. This is the first request for an extension. 2. I have been involved in trial preparation for State v. Kaylee Harrod, cause numbers CR14-28 1 and CRl 4- 323 , in Rusk County District Court set for Ap/rl 27 , 2015 (delivery of a controlled substance and endangering a child). Additionally' I've been working on trial preparation for State v. John Mumphrey, cause number 43486-A, in Gregg County District Court that had been set for trial April 20, 2015 (felony DWD. Furthermore, I have been involved in case preparation on State v. Jacob Roper, cause number t14-0320-15 & 114-0321-15 &,114-0322-l5,in smith county (two counts ofaggravated robbery and burglary ofa building)' 3. This motion is not made for purposes of delay, but so that justice may be done. granted. WHEREFORE, PREMISES CONSIDERED, the Appellant requests that this motion for be Re specJf-ully S ubmiued State Bar Number 24033153 ELLIS ANd SANDERS PLLC 120 S. Broadway Suite 112 Tyler, Texas 75702 Pirone (903)595-1 13 1 Fax (903)595-5532 CEhRTIFICATE OF SERVICE attorney This is to certiff that a true and correct copy of the foregoing Motion was served upon the for the State on 8TH of May,2A15. VERIFICATION STATE OF TEXAS $ $ KNOW ALL MEN BY THESE PRESENTS COUNTY OF SMITH $ .,My name is JEFF SANDERS and I am the attorney for the Appellant in this case. I have knowledge of the facts stated in the foregoing Motion and they are true and correct." Signed on 0rta.1 8 ,2a15. SWORN AND SUBSCRIBED TO BEFORE ME, the undersigned Notary Public on Glnot Atffi HoYtril fy Commtrrhn Erghrg April 26, 2016 Notary Public in and for the State of