Rendon, Michael Eric

PD-0015-15 COURT OF CRIMINAL APPEALS AUSTIN, TEXAS April 2, 2015 Transmitted 4/2/2015 11:47:09 AM Accepted 4/2/2015 12:49:08 PM ABEL ACOSTA NO. PD-0015-15 CLERK THE STATE OF TEXAS, § IN THE COURT OF Appellant vs. § CRIMINAL APPEALS MICHAEL ERIC RENDON, § AUSTIN, TEXAS Appellee MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRFIEF TO THE HONORABLE COURT OF CRIMINAL APPEALS: Now comes, Michael Eric Rendon, appellee in the instant cause, by and through undersigned counsel, Edward F. Shaughnessy, and files this Appellee’s Motion for Extension of Time to File Appellee’s Brief. In support of the instant motion the Appellee would show unto this Court the following: A. The Appellant is appealing a pre-trial ruling on a motion to suppress entered by the judge of the 377th District Court of Victoria County Texas wherein the trail Court entered an order suppressed certain evidence at the request of the appellee prior to trial in cause number 12-8-00666-CR. The Notice of Appeal was filed in a timely fashion in the trial Court. B. This is the appellee’s first request for an extension of time to file the appellee’s brief. The appellee’s brief is due to be filed in this Court on April 2 , 2015. C. The appellee respectfully requests an extension of time of thirty days until May 4, 2015 in which to file the appellee’s brief. D. The undersigned has recently filed briefs in the following matters: Jeffrey Lee v. The State of Texas, Cause No. 04-14-00256-CR; Israel Ytuarte Rodriguez v. The State of Texas, Cause No. PD-0278-14; Dustin Charles Wilmer v. The State of Texas, Cause No. 07-14-00266-CR. E. The undersigned is also in the process of compiling a brief on behalf of the appellant in the case of Jordan Lewis v. The State of Texas, Cause No. 01-14-00557-CR. Moreover the undersigned is in the process of filing a brief on behalf of the appellant in the case of Greg Saul v. The State of Texas 04-15- CR. F. In addition the undersigned serves as a part-time Criminal law Magistrate for the District Courts of Bexar County and as a Juvenile Referee for the Juvenile Courts of Bexar County. Counsel will be serving in those capacities during the upcoming days. G. The undersigned is scheduled to appear on behalf of The State of Texas on March 24, 2015 in the 38th Judicial District Court of Medina County for purposes of an evidentiary hearing in the case of Ex Parte Denise Crouch, a post-conviction writ of habeas corpus wherein this Court has ordered findings of fact and conclusions of law. Moreover, the undersigned is scheduled for a jury trial on March 16, 2015 in the 175th District Court of Bexar County, Texas in the case of The State of Texas v. Raymond Rose, cause number 2013-CR-6452. Rose is charged with 24 Counts of Aggravated Sexual Assault of a Child and Indecency with a Child. PRAYER FOR RELIEF Wherefore premises considered, the Appellee would request a thirty day extension of time file the brief in the instant case until May 4, 2015. Respectfully submitted, /S/ Edward F. Shaughnessy Edward F. Shaughnessy, III Attorney for the Appellee 206 East Locust Street San Antonio, Texas 78212 SBN: 18134500 Phone: (210) 212-6700 Fax: (210) 212-2178 Shaughnessy727@gmail.com CERTIFICATE OF SERVICE I, Edward F. Shaughnessy, hereby certify that a copy of the instant motion was served upon Brendan Wyatt Guy, attorney for the appellant, by mailing the motion to 205 N. Bridge St. Suite 301, Victoria, Texas 77901, on the _17_ day of March, 2015. /S/ Edward F. Shaughnessy Edward F. Shaughnessy, III Attorney for the Appellee