Jonathan Jose Guillen v. State ( 2015 )


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  •                                                                                                              ACCEPTED
    04-14-00772-CR
    FOURTH COURT OF APPEALS
    SAN ANTONIO, TEXAS
    7/16/2015 1:38:32 PM
    KEITH HOTTLE
    CLERK
    NO.     04- l4-00772-CR
    FILED IN
    4th COURT OF APPEALS
    JONATHAN JOSE GUILLEN                       SAN ANTONIO, TEXAS
    7/16/2015 1:38:32 PM
    VS.                         KEITH E. HOTTLE
    Clerk
    THE STATE OF TEXAS
    IN THE   COURT OF APPEALS
    FOURTH SUPREME JUDICIAL DISTRICT
    SAN ANTONIO, TEXAS
    MOTION FOR EXTENSION OF TIME TO FILE BRIEF
    TO THE HONORABLE JUDGE OF SAID COURT
    COMES NOW the Appellant JONATHAN JOSE GUILLEN, by and through his
    undersigned attorney, and respectfully requests that            this   Honorable Court allow him an
    extension of time for a period of thirty (30) days in which to file the Appellant's brief.
    The Appellant makes this request under 38.6(d) of the Texas Rules of Appellate
    Procedure, and shows the following in support of said motion:
    I
    The c1erk’s record in this cause was          electronically filed   on November 25, 2014.
    The Court Reporter’s record was         electronically filed     on April 28, 2015. Appe1lant’s brief
    is   due no   later than July 16,   2015. This   is   Appellant’s third motion for extension of time.
    ll
    The Appellant is            currently in custody.         He was   charged with the offense of murder
    in the 186th Judicial District Court in cause                 No. 2013CR2647 and was assessed ninety—
    nine (99) years        at   TDCJ on October         14, 2014.      Counsel was informed the brief was due
    on May 28, 2015. The record contains fourteen (14) volumes of testimony and                                legal
    documents.
    III
    This   is   the third extension requested           by the Appellant. The request for more time
    is   being   made not for the purposes of delay but rather so that justice may be done.
    IV
    Since the brief was due, counsel has completed thirty-seven pages of the Statement
    of Facts and made notes of sixteen potential points of error, which still need to be
    researched, and either included or excluded. Since the entry of the last Court's order
    granting an extension, counsel has                worked overtime and on weekends               to focus   on the
    completion of the           brief,   but also to effectively represent       all   other clients, in State and
    Federal courts, in and out of jails, inside and outside of Bexar County Courts, as well as
    assisting a colleague,          who recently underwent a very serious                surgery, with his cases.       The
    undersigned also has to return phone                calls   and make time for other cases and court
    appearances.         The undersigned        is   asking for a thirty (30) day extension but believes that
    the brief will be completed before then. This particular case                      is   fact-intensive with   many
    exhibits, pictures, as well as long videos              and telephone       calls.
    WHEREFORE, PREMISES CONSIDERED, the Appellant respectfully requests
    that this Court grant   an extension of thirty (30) days for the Appellant to file his Brief in
    this cause.
    Respectfully submitted,
    CAMPION & CAMPION
    fl//2
    ’ALEX J. 2?/PIA1iF%
    State Bar 0. 1772 5
    222 E. Main Plaza
    San Antonio, Texas 78205
    Telephone No. 210/227-5161
    Telecopier N0. 210/229-1243
    alex'ossc ahoo.com
    cind    cam ionlawfirmcom
    CERTIFICATE OF SERVICE
    This   is   to ceitify that a true   and correct copy of the foregoing Motion For
    Extension of Time      To File Brief has on this    16th day of July, 2015, been delivered to the
    Bexar County      District Atton1ey's Office,    San Antonio, Texas.
    4
    KLEX J. /§i4ARFF /       fl
    THE STATE OF TEXAS
    COUNTY OF BEXAR
    BEFORE ME, the undersigned authority, on this day personally appeared ALEX J                            .
    SCHARFF and after being duly sworn did depose and state:
    "My name is ALEX J. SCHARFF.                 I   am familiar with the foregoing Motion For
    Extension       Of Time To File Brief.   I   have read the foregoing document               to   which this
    affidavit   is   attached and believe the allegations contained therein are true and correct."
    WITNESS my signature this              if; day of      July,   20 1
    /    (
    SUBSCRIBED AND SWORN to before me on this                             [I
    day ofJuly, 2015.
    7
    C/L/)/Z"d44                  .
    /7 U/44/{4’hLA.-vv
    “Nov ME RRVMAN                                                                 ”
    My commission Expires            Notary Publicfin and for
    Femuarv14.2015                 the State of Texas
    My commission expires:              J /4 » 3
    —            /
    CERTIFICATE OF CONFERENCE
    I   certify that   on this       day of July, 2015,   I   spoke to Bexar County District
    Attorney, and advised       me that he is not opposed to any extensions of time sought by
    Appellant.
    ,4(LEX’J.            RFF
    /     5/
    

Document Info

Docket Number: 04-14-00772-CR

Filed Date: 7/16/2015

Precedential Status: Precedential

Modified Date: 9/28/2016