---------- -- ACCEPTED
04-15-00111-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
10/29/2015 2:37:09 PM
KEITH HOTTLE
CLERK
FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
10/29/2015 2:37:09 PM
KEITH E. HOTTLE
Clerk
No.04-15-00111-CR
IN THE
FOURTH COURT OF APPEALS
OF TEXAS
AT SAN ANTONIO, TEXAS
CLAUDIA CORTEZ APPELLANT
v. j
/
THE STATE OF TEXAS APPELLEE
,
EX S BRIEF IN
TO THE HONO LE JUSTICES OF THE COURT OF APPEALS,
FOURTH COURT OF APPEALS DISTRICT OF TEXAS:
COMES NOW, CLAUDIA CORTEZ, the appellant in the above styled and
•
numbered cause, pursuant to Texas Rules of Appellate Procedure 10.5(b) and
38.6( d), through her attorney of record, files this motion to extend time to file the
Appellant's Motion for Rehearing and Brief in Support of Motion for Rehearing. In
support of this motion the appellant respectfully shows the following:
I. Deadline for filing the appellant's brief:
The current deadline for filing the motion for rehearing is October 29, 2015.
TEX.R.App.P. 4.1(a) and 38.6(a)(2).
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II. Length of the extension sought:
Counsel for appellant seeks one thirty (30) day extension to file the
appellant's Motion for Rehearing and Brief in Support of Motion for Rehearing,
until November 30,2015. See TEX.R.APp.P. 4.1(a).
III. Facts relied on to reasonably explain request for extension:
Counsel for appellant seeks this extension of time to file the appellant's
)
motion and brief for the following reasons:
A. Counsel for appellant was retained on October 14, 2015, and the undersigned
,
needs time to prepare the Motion for a Rehearing.
B. Counsel for appellant had set for trial in the following cases:
1. ITIO Isaiah Martinez, et al, 2014-PA-02688 set for Trial on the Merits on
October 26,2015.
2. The State a/Texas v. Richard Aguillon, 2015-CR-8584 and 2015-CR-7000
set for October 27,2015.
IV. Number of previous extensions requested:
This is the first extension of time requested in this case.
V. Not for delay:
This extension of time is not sought for the purpose of delaying the resolution
of this appeal. Undersigned counsel does not believe the additional time requested
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will prejudice or inconvenience the State.
VI. Appellant's status:
The Appellant is presently on bond.
PRAYER
THEREFORE, counsel for the appellant prays that this Court issue an order
)
granting the extension of time of thirty (30) days to file the appellant's brief in
support of a Rehearing in the above case, and grant all such relief as is fair and just.
,
Respectfully submitted,
Alberto Elias Chaires
Texas Bar No. 24050401
The Law Office of Alberto Elias Chaires
111 Soledad, Suite 300
San Antonio, Texas 78205
(210) 299-7619
(210) 714-9145 fax
aechaires@gmail.com
ALBERTO ELIAS CHAIRES
ATTO Y FOR APPELLANT
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CERTIFICATE OF SERVICE
The undersigned does hereby certify that a copy of the above motion was
delivered to the State's Attorney: Nico LaHood, Criminal District Attorney, Bexar
County District Attorney's Office, Appellate Section, 101 W. Nueva St., Suite 370,
San Antonio, Texas 78205, on October 29,2015.
ALBERTO ELIAS CHAI
,
,
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