Jeffrey Lee v. State ( 2014 )

ACCEPTED
04-14-00256-CR
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
12/29/2014 4:43:33 PM
KEITH HOTTLE
CLERK
NO. 04-14-00256-CR
FILED IN
4th COURT OF APPEALS
JEFFREY LEE, § TEXAS COURT SAN
OF ANTONIO,
APPEALS TEXAS
Appellant 12/29/2014 4:43:33 PM
KEITH E. HOTTLE
vs. § FOURTH COURT Clerk
THE STATE OF TEXAS, § SAN ANTONIO, TEXAS
Appellee
A MOTION FOR EXTENSION OF
TIME TO FILE APPELLANT’S BRFIEF
TO THE HONORABLE COURT OF APPEALS:
Now comes the Jeffrey Lee, appellant in the instant cause, by and
through the undersigned counsel, Edward F. Shaughnessy, and files this
Appellant’s Motion for Extension of Time to File Appellant’s Brief. In
support of the instant motion the Appellant would show unto this Court the
following:
A.
The Appellant is appealing the judgment of the 187th District Court of
Bexar County, Texas wherein he was convicted, following a jury trial of the
offense of Aggravated Robbery. The Appellant was sentenced to twenty-five
(25) years of confinement in the Institutional Division of the Texas
Department of Criminal Justice.
B.
The undersigned has filed one previous motion for extension fo time
to file the appellant’s brief in the instant case.
C.
The appellant’s brief is due to be filed in this Court on or before
December 29, 2014.
D.
The undersigned has recently filed briefs in the following matters:
Dustin Charles Wilmer v. The State of Texas, Cause No. 07-14-00266-CR;
Joseph Lester Green v. The State of Texas, Cause No. PD-0738-CR; and
Billy Dean Butler v. The State of Texas, Cause No. 0456-CR.
E.
The undersigned is also in the process of compiling a brief on behalf
of the appellee in the case of Edgar Javier Gonzales, Cause No. 04-14-
00100-CR. Moreover the undersigned is in the process of filing briefs on
behalf of the appellant in the cases of Ruben Andres Baldez v. The State of
Texas, Cause No. 13-14-00257-CR; and Alvin Valadez v. The State of
Texas, Cause No. 04-14-00626-CR.
F.
In addition the undersigned serves as a part-time Criminal law
Magistrate for the District Courts of Bexar County and as a Juvenile Referee
for the Juvenile Courts of Bexar County. Counsel recently spent a number
of days serving in those capacities.
PRAYER FOR RELIEF
Wherefore premises considered, the Appellee would request a thirty
day extension of time file the brief in the instant case until January 28, 2015.
Respectfully submitted,
/S/ Edward F. Shaughnessy
Edward F. Shaughnessy, III
Attorney for the Appellee
206 East Locust Street
San Antonio, Texas 78212
SBN: 18134500
Phone: (210) 212-6700
Fax: (210) 212-2178
Shaughnessy727@gmail.com
CERTIFICATE OF SERVICE
I, Edward F. Shaughnessy, hereby certify that a copy of the instant
motion was served upon Susan D. Reed, attorney for the appellee, by
mailing the motion to 101 W. Nueva, Suite 307 San Antonio, Texas 78205
on the _29_ day of December, 2014.
/S/ Edward F. Shaughnessy
Edward F. Shaughnessy, III
Attorney for the Appellant