Edgar Sangillo v. State

ACCEPTED 03-15-00410-CR 8302798 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/18/2015 2:28:13 PM JEFFREY D. KYLE CLERK NO. 03-15-00410-CR FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS IN THE COURT OF APPEALS 12/18/2015 2:28:13 PM FOR THE JEFFREY D. KYLE THIRD SUPREME JUDICIAL DISTRICT Clerk AT AUSTIN, TEXAS EDGAR SANGILLO, Appellant vs. THE STATE OF TEXAS, Appellee Appeal from the 299th Judicial District Court Cause No. D-1-DC-12-200962 Travis County, Texas The Honorable Karen R. Sage, Judge Presiding APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME Gary E. Prust State Bar No. 24056166 1607 Nueces Street Austin, Texas 78701 (512) 469-0092 Fax: (512) 469-9102 gary@prustlaw.com ATTORNEY FOR APPELLANT ORAL ARGUMENT IS NOT REQUESTED APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF Appellant, Edgar Sangillo, files this, his “First Motion for Extension of Time to File Brief,” and in support thereof shows as follows. I. 1. Appellant's Motion is brought pursuant to TEX.R.APP.P 10.5(b). 2. Appellant has not requested previously an extension of time within which to file his brief. 3. Appellant's brief is due on December 23, 2015. 4. Appellant's attorney was appointed by order of the trial court to represent Appellant in this cause and the companion case in cause number 03-15-00411-CR on December 16, 2015. Appellant has multiple trial court settings and other appeals due in the near future. 5. In order to address the issues raised in the present appeal thoroughly, Appellant's attorney will require more time to complete his brief. Appellant’s attorney will require until January 23, 2016 to complete his brief. 6. Accordingly, Appellants request that this Court allow him until January 23, 2016 to file his brief. Respectfully submitted, Gary E. Prust SBN 24056166 1607 Nueces Street Austin, Texas 78701 (512) 469-0092 Fax: (512) 469-9102 gary@prustlaw.com Attorney for Appellant CERTIFICATE OF SERVICE In compliance with Rule 9.5(d) of the Texas Rules of Appellate Procedure, the undersigned attorney certifies that a true and correct copy of the foregoing Motion was served on the Travis County District Attorney via facsimile transmission to 512-854-9695 on this 18th day of December, 2015. Gary E. Prust CERTIFICATE OF CONFERENCE In compliance with Rule 10.1(a)(5) of the Texas Rules of Appellate Procedure, the undersigned attorney certifies he conferred with the Travis County District Attorney’s office before filing this motion, and they expressed no opposition to this motion. Gary E. Prust CERTIFICATE OF COMPLIANCE Pursuant to TEX. R. APP. PROC. 9.4(i)(3), I hereby certify this brief contains 152 words. This is a computer-generated document created in Microsoft word, using 14-point typeface. In making this this certificate, I rely on the word county provided by the software use to prepare the document. Gary E. Prust