PD-1647-15 PD-1647-15
COURT OF CRIMINAL APPEALS
AUSTIN, TEXAS
Transmitted 12/18/2015 2:11:25 PM
Accepted 12/19/2015 10:38:29 AM
COURT OF CRIMINAL APPEALS CASE NO.: __________________________ABEL ACOSTA CLERK
FOURTH COURT OF APPEALS CASE NUMBER 04 – 14 – 00565 – CR
TRIAL COURT CASE NUMBER 2009 – CRP – 000403 – D1
RODOLFO MARTINEZ– SALINAS § COURT OF CRIMINAL APPEALS
§
v. §
§
THE STATE OF TEXAS § TRAVIS COUNTY, TEXAS
RODOLFO MARTINEZ – SALINAS’ FIRST MOTION FOR EXTENSION
OF TIME TO FILE PETITION FOR DISCRETIONARY REVIEW
TO THE HONORABLE JUSTICES OF THE COURT OF CRIMINAL APPEALS
201 W 14TH STREET
AUSTIN, TEXAS 78701 – 1445
Richard J. Gonzalez, the undersigned counsel for Appellant Rodolfo
Martinez – Salinas, has been unable to complete the Petition for Discretionary
Review on or before the deadline to file it.
The deadline to file the Petition for Discretionary Review was Friday,
December 4, A.D., 2015.
The length of the extension sought is from Friday, December 4, A.D., 2015,
to Monday, January 18, A.D., 2016, a total of forty - five (45) days.
The facts relied on to reasonably explain the need for an extension are:
Between November 4, A.D., 2015, and December 18, A.D., 2015, counsel
for Rodolfo Martinez – Salinas was scheduled for a court appearance in more than
eighty – five (85) cases in Laredo, Webb County, Texas, and was scheduled for a
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December 18, 2015
jury trial in at least two cases during that period, which jury trials were avoided
because the defendant in each case eventually entered a plea of guilty.
Counsel for Rodolfo Martinez – Salinas was engaged in a jury trial in the
case styled, “The State of Texas v. Juan Carlos Palomares,” Trial Court Cause
Number: 2015CRS000530 D4, Court of Appeals Number 04 – 15 – 00755 – CR,
which jury trial ended on October 28, A.D., 2015, and counsel filed the Notice of
Appeal, and Designation of Clerk’s and Reporter’s Records on Appeal on
November 30, A.D., 2015.
Counsel for Rodolfo Martinez – Salinas is scheduled for a jury trial in Cause
Number 2015CRP000624 D4, styled “The State of Texas v. Jessica Lee Carreon,”
on Monday, January 11, A.D., 2015.
There have been no previous extensions granted regarding the Petition for
Discretionary Review.
The Court of Appeals is the Fourth (4th) Court of Appeals in San Antonio,
Bexar County, Texas.
The date of the Court of Appeals’ judgment is Wednesday, November 4,
A.D., 2015.
The case number and style of the case in the Court of Appeals are:
Case Number: 04 – 14 – 00565 – CR.
Style: Rodolfo Martinez – Salinas v. The State of Texas.
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There were no motions for rehearing or en banc reconsideration filed in the
Fourth Court of Appeals.
Wherefore, premises considered, counsel for Rodolfo Martinez – Salinas
respectfully requests an extension of time to file the Petition for Discretionary
Review from Friday, December 4, A.D., 2015 to Monday, January 18, A.D., 2016.
Respectfully submitted,
Digitally signed by RICHARD J.
GONZALEZ
DN: cn=RICHARD J. GONZALEZ, o, ou,
email=RICHARD0477@SBCGLOBAL.NE
T, c=US
Date: 2015.12.18 13:58:38 -06'00'
___________________________________________________
RICHARD J. GONZALEZ
ATTORNEY AT LAW
TEXAS BAR NUMBER 08131600
910 LOGAN AVENUE
LAREDO TX 78040 – 6202
CELL: (956) 401 – 6011
VOICE MAIL: (956) 307 – 9910
EMAIL: RICHARD0477@SBCGLOBAL.NET
CERTIFICATE OF SERVICE
I, Richard J. Gonzalez, counsel for Rodolfo Martinez – Salinas, do hereby
certify, under oath, that I emailed a true and correct copy of the above and
foregoing “Rodolfo Martinez – Salinas First Motion for Extension of Time to File
The Petition for Discretionary Review” to David Reuthinger, Jr., Assistant District
Attorney, 49th Judicial District of Texas, 1110 Victoria Street Suite 401, PO Box
1343, Laredo, Webb County, Texas, 78042 – 1343, (956) 523 – 4900, at
dreuthinger@webbcountytx.gov, on Friday, December 18, A.D., 2015.
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Digitally signed by RICHARD J. GONZALEZ
DN: cn=RICHARD J. GONZALEZ, o, ou,
email=RICHARD0477@SBCGLOBAL.NET, c=US
Date: 2015.12.18 13:59:08 -06'00'
___________________________________________________
RICHARD J. GONZALEZ
COUNSEL FOR RODOLFO MARTINEZ – SALINAS
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