ACCEPTED
04-14-00772-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
10/16/2015 2:56:35 PM
KEITH HOTTLE
CLERK
NO. 04-14-00772-CR
§ IN THE FOURTH DISTRICT
JONATHAN JOSE GUILLEN §
§
VS. § COURT OF APPEALS
§
§
STATE OF TEXAS § SAN ANTONIO, TEXAS
MOTION FOR EXTENSION OF TIME
TO FILE STATE’S BRIEF
TO THE HONORABLE JUDGES OF THE FOURT COURT OF APPEALS:
NOW COMES Nicholas “Nico” LaHood, Criminal District Attorney of
Bexar County and Counsel for the State of Texas, and files this Motion asking that
the Court extend the time for filing the State’s brief.
On October 9, 2014, a jury found Appellant guilty of murder. On October
14, 2014, the jury sentenced Appellant to 99 years in the Texas Department of
Criminal Justice, Institutional Division. Appellant filed a notice of appeal on
November 3, 2014. Appellant filed a Motion for New Trial on November 12, 2014
and it was denied by the trial court on November 18, 2014. The reporter’s record
was filed on April 28, 2015. Appellant filed his brief on August 17, 2015. After a
first extension of time, the State’s brief was due October 16, 2015. This is the
State’s second motion requesting an extension of time and the State requests a 30
day extension to November 16, 2015.
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This extension is not sought for the purpose of delaying this appeal. The
State requests an extension for the following reasons:
1) Counsel would like more time to thoroughly read the record in this case,
as well as to research and write the State’s brief. The reporter’s record in
this case is voluminous and consists of fourteen volumes.
2) Counsel recently filed the following briefs in the Fourth Court of
Appeals:
a. State of Texas v. Charles Caves, No. 04-15-00367-CR.
b. In the Interest of C.F.N., A Child, No. 04-15-00458-CV.
Therefore, counsel respectfully asks the Court to grant this extension of
time to file the State’s brief in this case.
WHEREFORE, PREMISES CONSIDERED, Counsel for the State prays
that the Court grant an extension of time to November 16, 2015 for filing the
State’s brief.
Respectfully submitted,
Nicholas “Nico” LaHood
Criminal District Attorney
Bexar County, Texas
/s/ Jennifer Rossmeier Brown
____________________
Jennifer Rossmeier Brown
State Bar No. 24079247
Assistant Criminal District Attorney
101 W. Nueva Street
San Antonio, Texas 78205-3030
Phone: (210) 335-2734
Fax: (210) 335-2436
Email: jennifer.rossmeier@bexar.org
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CERTIFICATE OF SERVICE
I certify that a true copy of the above was served on the attorney of record in
accordance with the Texas Rules of Appellate Procedure on October 16, 2015, in
the manner described below:
Via Electronic Service
Alex J. Scharff
222 E. Main Plaza
San Antonio, Texas 78205
alexjoss@yahoo.com
Via Electronic Service
Alan Brown
222 Main Plaza E
San Antonio, Texas 78205
alan@brownandnorton.com
/s/ Jennifer Rossmeier Brown
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