Moises Renteria v. State ( 2015 )

ACCEPTED
06-15-00106-CR
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
9/16/2015 7:18:39 PM
DEBBIE AUTREY
CLERK
No. 06-15-00106-CR
IN THE COURT OF APPEALS FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
FOR THE SIXTH APPELLATE DISTRICT
9/17/2015 8:12:00 AM
DEBBIE AUTREY
TEXARKANA, TEXAS Clerk
MOISES RENTERIA APPELLANT
VS
STATE OF TEXAS APPELLEE
MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANT
TO HONORABLE JUDGES OF SAID COURT:
NOW COMES, the Appellant by and through his Attorney, Tim Cone, and does
hereby move this Honorable Court to grant an extension of time for the purpose of filing
the Appellant’s Brief.
I.
Judgment was entered with the 188th District Court of Gregg County, Texas, in
Cause Number 38,802-A styled The State of Texas vs. Moises Renteria, on the 1st day
of August, 2011. An out of time appeal was granted by the Texas Court of Criminal
Appeals on June 15, 2015. The Appellant’s brief is due on September 17, 2015. This is
the Appellant’s first request for an extension of time for the late filing of Appellant’s
brief.
Appellant’s attorney requests an extension of time for late filing of a brief until
October 17th, 2015, and will, hopefully be the last request for extension of time for late
filing of said brief and would show to the Court the following: Appellant’s attorney was
on a prepaid vacation from August 21, 2015, through August 30, 2015. Unfortunately,
upon returning from said vacation, Appellant’s attorney contracted pneumonia and was
very ill for about 10 days. A great deal of work stacked up during the time of the
vacation and ensuing illness. Further, Appellant’s attorney has recently submitted a brief
to this Court in the case of Derek Clinton Ward, Case 06-15-00110-CR. Further,
although it may be irrelevant, the extension in the case at bar is likely in relation to the
last brief Appellant’s attorney will submit to this Court due to an impending retirement.
WHERWFORE, PREMISES CONSIDERED, Appellant’s attorney respectfully
requests that this Honorable Court grant Appellant’s request for an Extension to file a
late brief until October 17, 2015.
. Respectfully Submitted,
/s/Tim Cone
______________________________
Tim Cone, Attorney At Law
State Bar N. 04660350
P.O. Box 413
Gilmer, Texas 75644
903-725-6270
e-mail: timcone6@aol.com
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing
Appellant’s Motion for Extension of Time to File Brief has been served to Zan Brown,
Assistant Criminal District Attorney for Gregg County, attorney for Appellee, on this
the 16th day of September, 2015.
/s/Tim Cone
_____________________________
Tim Cone, Attorney At Law