ACCEPTED
04-15-00602-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
12/16/2015 11:57:35 AM
KEITH HOTTLE
CLERK
IN THE FOURTH COURT OF APPEALS
FOR THE STATE OF TEXAS
FILED IN
4th COURT OF APPEALS
ROGER TRUDELL DAVIS SAN ANTONIO, TEXAS
12/16/15 11:57:35 AM
V. NO. 4-15-00602-CR
KEITH E. HOTTLE
Clerk
THE STATE OF TEXAS
APPELLANT’S FIRST MOTION FOR
EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE FOURTH COURT OF APPEALS:
COMES NOW, Roger Trudell Davis, by and through his attorney of record, Karen
Oprea, and files this his First Motion for Extension of Time to File Brief and in support
thereof, would show the Court the following:
I.
That the above-styled and numbered cause is styled The State of Texas v. Roger
Trudell Davis, Cause Number 2015CR4694 in the 187th Judicial District Court of Bexar
County, Texas. Appellant was sentenced on September 15, 2015.
II.
Appellant was convicted of the offense of assault (family/dating violence) second
offense, and punishment was assessed at thirty (30) years, a $1,000 fine, and court costs.
III.
Appellant’s motion for new trial was filed on September 22, 2015. Notice of appeal
was filed on September 25, 2015. The reporter’s record was filed on November 17, 2015,
and the clerk’s record was filed on October 19, 2015. The due date for the brief is
Thursday, December 17, 2015.
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IV.
This is Appellant’s first motion for extension of time to file his brief. Appellant
respectfully requests a forty day extension of time to file the brief, which would make such
brief due on Monday, January 25, 2016.
V.
The undersigned attorney has read the record in this case and has started drafting
the brief but has been unable to complete the brief due to a death in her family, which
required time away from her practice and travel out of state.
In addition, the undersigned attorney identified an item missing from the clerk’s
record and has requested it from the trial court. Receipt of this item is necessary to complete
Appellant’s brief. She asks that this extension be granted so that she may effectively
represent Appellant and so that justice may be done in this case.
Respectfully Submitted,
/s/ Karen E. Oprea
KAREN E. OPREA
The Law Office of Oprea & Weber
510 N. IH35
AUSTIN, TEXAS 78702
(512) 485-3003
(512) 597-1658 (Fax)
SBN: #24090307
ATTORNEY FOR MR. ROGER
DAVIS (COURT-APPOINTED)
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CERTIFICATE OF COMPLIANCE
I hereby certify that this motion was computer generated and contains 377 words,
as calculated by the word count function on my computer.
/s/ Karen E. Oprea
KAREN E. OPREA
CERTIFICATE OF SERVICE
I, Karen E. Oprea, hereby certify that a true and correct copy of the foregoing
Appellant’s First Motion for Extension of Time to File Brief was sent by email to Clarissa
Fernandez at clarissa.fernandez@bexar.org on this 16th day of December, 2015.
/s/ Karen E. Oprea
KAREN E. OPREA
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