ACCEPTED
04-15-00080-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
8/4/2015 4:19:15 PM
KEITH HOTTLE
CLERK
NO. 04-15-00080-CR
IN THE FOURTH COURT OF APPEALS
FILED IN
OF TEXAS 4th COURT OF APPEALS
SAN ANTONIO, TEXAS
SAN ANTONIO, TEXAS
08/04/15 4:19:15 PM
KEITH E. HOTTLE
Clerk
JERRY LEE TRIGO,
APPELLANT
V.
STATE OF TEXAS,
APPELLEE
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MOTION FOR EXTENSION TO FILE APPELLANT’S WITHDRAWAL OF NOTICE
OF APPEAL
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ON APPEAL FROM THE 229TH DISTRICT COURT OF DUVAL COUNTY, TEXAS,
NO. 14-CRD-52
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TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW JERRY LEE TRIGO the Appellant in the above-entitled and numbered
cause, by and through his attorney of record, CALIXTRO VILLARREAL, JR., before a
decision has been rendered by this Court, and respectfully moves this Court to extend the time
for Defendant to file Appellant’s Withdrawal of Notice of Appeal, and shows as follows:
I.
Appelant’s Brief is due in this Court on August 10, 2015
II.
Appellant wishes to file a Withdrawal of Notice of Appeal in this cause.
III.
It was never the intention of Appellant Counsel to file for appeal, but Appellant Counsel
was hired after Trial Counsel had filed the Notice of Appeal.
IV.
Appellant’s Withdrawal of Notice of Appeal requires Appellant’s signature and counsel
is eight (8) hours away from Robertson Unit in Abilene, Texas where Appellant is currently
incarcerated. Counsel will make his best effort to visit with Appellant and acquire his signature.
WHEREFORE PREMISE CONSIDERED, Appellant prays that this Court extend Appellant’s
filing deadline from August 10, 2015 to August 17, 2015 to allow for Counsel to submit
Appellant’s Withdrawal of Notice of Appeal.
Respectfully submitted,
CALIXTRO VILLARREAL, JR.
205 W. Main Street
Rio Grande City, Texas 78582
Telephone No.: (956) 487-3739
Facsimile No.: (956) 487-8670
By: __/s/ Calixtro Villarreal_____
Calixtro Villarreal
State Bar No.: 20581905
Attorney for Defendant
CERTIFICATE OF SERVICE
I, Calixtro Villarreal, Jr., Attorney for the Defendant in the above and foregoing
WITHDRAWAL OF NOTICE OF APPEAL do hereby certify that a copy of the same has been
forwarded to same has been forwarded to the District Attorneys of Duval County, P.O. Box Drawer
1061, San Diego, TX 78384, before 5:00 o’clock p.m. time of the recipient on the 4th day of August,
2015
____/s/ Calixtro Villarreal____
Calixtro Villarreal Jr