ACCEPTED
04-14-00709-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
4/2/2015 10:38:51 AM
KEITH HOTTLE
CLERK
Nos. 04-14-00709-CR
STATE OF TEXAS § IN THE COURT OF APPEALS
FILED IN
4th COURT OF APPEALS
VS. § SAN ANTONIO,
FOURTH JUDICIAL TEXAS
DISTRICT
4/2/2015 10:38:51 AM
FRANCISCO JAVIER GONZALEZ § BEXAR COUNTY,
KEITHTEXAS
E. HOTTLE
Clerk
MOTION FOR EXTENSION OF TIME
TO FILE OPENING BRIEF
From the 399th District Court of Bexar County, Texas
Trial Court No. 2011-CR-9697
Hon. Ray J. Olivarri, Judge Presiding
In accordance with Tex. R. App. P. 10.5(b), the undersigned submits the following:
Appellant’s brief is due to be filed on Monday, the 6th of April, 2015. The undersigned
requests additional time to prepare and file Appellant’s opening brief. Counsel has recently
received the trial court’s findings of fact and conclusions of law, tendered to counsel on March
31, 2015. Counsel has been working on Appellant’s brief but needs time to incorporate the
court’s ruling and amend his arguments. Counsel has also been preparing two writs of habeas
corpus, one in Bexar County and one in Dallas County, which have forced counsel to divert his
attention from this appeal. Counsel requests an extension of twenty-one (21) days, to and
including Monday, April 27, 2015. This is Appellant’s third request for an extension.
Appellant has spoken with the Bexar County District Attorney’s Office regarding
this motion and, per Chief Appellate Prosecutor RicoValdez, they are not opposed to
granting this request for an extension of time.
WHEREFORE, PREMISES CONSIDERED, Appellant respectfully requests that this
Court grant the requested extension.
Respectfully submitted,
Robert A. Jimenez
De Mott, McChesney, Curtright & Armendariz, LLC.
800 Dolorosa Street, Suite 100
San Antonio, Texas 78207
210/354-1844
210/212-2116 - fax
By: /s/ Robert A. Jimenez
SBN: 24059125
CERTIFICATE OF SERVICE
I hereby certify that on this the 24th day of April, 2015 a copy of the foregoing “Motion
for Extension of Time to File Appellant’s Opening Brief” has been electronically filed with this
Court, and will be served to the Bexar County District Attorney’s Office on April 2, 2015.
/s/ ROBERT A. JIMENEZ