PD-0235&0236
COURT OF CRIMINAL APPEALS
PD-0235-15 & PD-0236-15 AUSTIN, TEXAS
Transmitted 2/27/2015 5:41:45 PM
Accepted 3/2/2015 11:48:22 AM
ABEL ACOSTA
NO. PD-__________ AND PD-____________ CLERK
IN THE COURT OF CRIMINAL APPEALS OF THE STATE OF TEXAS
ELIAS ESEQUIEL VASQUEZ, Appellant
vs.
THE STATE OF TEXAS, Appellee
APPELLANT VASQUEZ’S MOTION
FOR EXTENSION OF TIME TO FILE PDR IN APPELLATE
CAUSE NOS. 04-13-00338-CR AND 04-13-00339-CR
Respectfully submitted by
Appellant's attorney,
VICTORIA GUERRA
Texas Bar No. 08578900
3219 N. McColl Rd.
McAllen, Texas 78501
(956) 618-2609
(956) 618-2553 Fax
March 2, 2015
MAY IT PLEASE THE COURT:
COMES NOW Elias Esequiel Vasquez, Appellant in the above styled
cause, and files this motion for extension of time to file his PDRs, and
would show this Court the following:
At 2:00 a.m. on February 18, 2015, the Undersigned filed an
appellant’s brief in the Thirteenth Court of Appeals in the case of State v.
Chakravarthy, Cause No. 13-14-00086-CR. Its record consisted of over
8,000 pages and the brief contained over 9 issues, plus sub-parts. At 4:00
a.m., the Undersigned had to go to Austin to attend a mandatory training
for Independent Hearing Examiners for the Texas Education Agency. The
Undersigned stayed in Austin the rest of that week taking care of sundry
business matters. The Undersigned returned from Austin on February 22,
2015. Up to today, the Undersigned has been catching up with her many
other cases that were put on the back burner until the aforementioned brief
was filed. As such, Appellant seeks an extension of time to file this PDR to
this day, February 27, 2015.
WHEREFORE, Appellant prays that this Court grant his motion for
extension of time to file his PDRs.
Respectfully submitted,
Law Office of Victoria Guerra
3219 N. McColl Rd.
McAllen, Texas 78501
(956) 618-2609
(956) 618-2553 (facsimile)
By: /s/ Victoria Guerra
Victoria Guerra
State Bar Number: 0857900
Appellate Attorney for Appellant
CERTIFICATE OF SERVICE
On this 27th day February, 2015, the undersigned delivered a copy of
the foregoing Appellant’s motion for extension of time to file Appellant’s
brief to Appellee’s Counsel jaolson_ccda@yahoo.com or his facsimile: 210-
858-6780 and to the State Prosecuting Attorney at its fax: (512) 463-5724.
/s/ Victoria Guerra
Victoria Guerra, Attorney for Appellant
CERTIFICATION OF COMPLIANCE
In compliance with TRAP 9.4(i)(3), the undersigned certifies that the
number of words in this brief, excluding those matters listed in Rule 9.4(i)
(l), is 191.
/s/ Victoria Guerra
Victoria Guerra