ACCEPTED
No. 01-14-00982-CR
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/10/2015 1:16:05 PM
CHRISTOPHER PRINE
CLERK
No. 01-14-00982-CR
In the FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
Court of Appeals 4/10/2015 1:16:05 PM
CHRISTOPHER A. PRINE
Clerk
For the
First District of Texas
At Houston
_________________________________________________________
Trial Court Cause No. 13378054
In the 338th District Court
of Harris County, Texas
_________________________________________________________
JUAN CARLOS BARRERA-MAGANA,
Appellant
v.
THE STATE OF TEXAS,
Appellee
___________________________________________________________
MOTION FOR EXTENSION OF TIME TO FILE
__________________________________________________________
VIVIAN R. KING
State Bar No. 00784399
2202 Alabama St.
Houston, Texas 77004
(713) 222-2019 Office
(877) 753-6706 eFax
Appointed Attorney for Appellant
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TO THE HONORABLE COURT OF APPEALS:
NOW COMES JUAN CARLOS BARRERA-MAGNA, the Appellant
herein, and moves the Court for an extension of time to file Appellant's Brief in this
cause, pursuant to TEX. R. APP. PROC. Rules 10.5 (b)(2) and 38.6(n), and in
support thereof would show the Court as follows:
I.
The Appellant in this cause was convicted by a jury of Murder in the 338th
District Court of Harris County, Texas in cause number 1338054 and his sentence
was assessed at Life in Prison in the Texas Department of Corrections, Institutional
Division. Notice of Appeal was properly filed on December 04, 2014.
II.
The Clerk’s record was properly filed on January 28, 2015.
The Reporter’s record was filed on February 28, 2015.
Appellant’s brief was due on April 01, 2015.
This is a voluminous record. The case is complicated.
III.
No previous extensions have been filed.
Appellant’s attorney is requesting a 60-day extension of time to file
Appellant’s Brief to June 01, 2015.
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IV.
Appellant’s attorney is requesting this extension of time to file Appellant’s
Brief due to multiple trial settings that are demanding an enormous amount of
preparation time.
This motion is not made for delay, but instead, to ensure effective assistance
of counsel.
WHEREFORE, PREMISES CONSIDERED, the undersigned counsel, on
behalf of Appellant, respectfully prays that this Honorable Court grant this extension
to June 01, 2015.
RESPECTFULLY SUBMITTED,
/s/ Vivian R. King
VIVIAN R. KING
Texas Bar No. 00784399
2202 Alabama St.
Houston, Texas 77004
(713) 222-2019 office
(877) 753-6706 e Fax
VivianRKing@msn.com Email
CERTIFICATE OF SERVICE
As Attorney of Record for Appellant, I do hereby certify that a true and correct
copy of the above and foregoing document was emailed to Appellate Division and
efiled with the office of the Honorable Devon Anderson, Harris County District
Attorney, on April 10, 2015.
/s/ Vivian R. King
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