ACCEPTED
04-14-00772-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
6/29/2015 11:29:28 AM
KEITH HOTTLE
CLERK
NO. O4-14-00772-CR
FILED IN
4th COURT OF APPEALS
JONATHAN JOSE GUILLEN SAN ANTONIO, TEXAS
6/29/2015 11:29:28 AM
VS. KEITH E. HOTTLE
Clerk
THE STATE OF TEXAS
IN THE COURT OF APPEALS
FOURTH SUPREME JUDICIAL DISTRICT
SAN ANTONIO, TEXAS
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUDGE OF SAID COURT
COMES NOW the Appellant JONATHAN JOSE GUILLEN, by and through his
undersigned attorney, and respectfully requests that this Honorable Court allow him an
extension of time for a period of forty—five (45) days in which to file the Appellant's brief.
The Appellant makes this request under 38.6(d) of the Texas Rules of Appellate
Procedure, and shows the following in support of said motion:
I
The clerk’s record in this cause was electronically filed on November 25, 2014.
The Court Reporter’s record was electronically filed on April 28, 2015. Appe1lant’s brief
is due no later than June 29, 2015. This is Appellant’s second motion for extension of
time.
II
The Appellant is currently in custody. He was charged with the offense of murder
in the 186th Judicial District Court in cause No. 2013CR2647 and was assessed ninety-
nine (99) years at TDCJ on October 14, 2014. Counsel was infonned the brief was due
on May 28, 2015. The record contains fourteen (14) volumes of testimony and legal
documents.
III
This is the second extension requested by the Appellant. The request for more
time is being made not for the purposes of delay but rather so that justice may be done.
WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully requests
that this Court grant an extension of forty-five (45) days for the Appellant to file his Brief
in this cause.
Respectfully submitted,
CAMPION & CAMPION
<1
ALEX J. so
State Bar
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0.177 350 /
222 E. Main Plaza
San Antonio, Texas 78205
Telephone No. 210/227-5161
Telecopier No. 210/229-1243
alex'oss ahoo.com
cind cam ionlawfi1m.com
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing Motion For
Extension of Time To File Brief has on this 29th day of June, 2015, been delivered to the
Bexar County District Attorney's Office, San Antoni
,ALEX
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J.
THE STATE OF TEXAS
COUNTY OF BEXAR
BEFORE ME, the undersigned authority, on this day personally appeared ALEX J.
SCHARFF and after being duly sworn did depose and state:
"My name is ALEX J. SCHARFF. I am familiar with the foregoing Motion For
Extension Of Time To File Brief. I have read the foregoing document to which this
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affidavit is attached and believe the allegations contained therein are true and correct."
4
WITNESS my signature this L 6 day of June, 2015.
/ALEX J.
SUBSCRIBED AND SWORN to before me on this 92 day oflune, 2015.
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CERTIFICATE OF CONFERENCE
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on day of June, 2015, I spoke to Bexar County District
. . . .
I certify that this
Attorney, and advised me that he is not opposed to any extensions of time sought by
Appellant.
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