Jose Julio Sanchez v. State ( 2015 )

ACCEPTED
12-14-00324-CR
TWELFTH COURT OF APPEALS
TYLER, TEXAS
4/30/2015 12:06:29 PM
CATHY LUSK
CLERK
NO. 12-14-00324-CR
JOSE JULIO SANCHEZ § IN THE COURT OF APPEALS
FILED IN
Appellant § 12th COURT OF APPEALS
TYLER, TEXAS
§ 4/30/2015 12:06:29 PM
V. § 12th COURT OFCATHY
APPEALS
S. LUSK
§ Clerk
THE STATE OF TEXAS §
Appellee § TYLER, TEXAS
APPELLANT'S REQUEST FOR EXTENSION TO FILE BRIEF
TO THE HONORABLE COURT OF APPEALS:
NOW COMES Appellant before this Court, and Defendant in the Trial Court
in Cause Number before the 2nd Judicial District Court, Cherokee County, Texas,
and files this his Motion for Extension to File Brief, pursuant to Rules 10.5(b) and
38.6 (d) of the Texas Rules of Appellate Procedure, and for same would show unto
the Court as follows, to-wit:
I.
First Motion:
This is Appellant first motion for extension of the deadline for the filing of
Appellant’s Brief.
II.
Original Brief Deadline:
Appellant’s Brief was due to be filed on or before April 30, 2015.
III.
Sexual Assault Conviction:
Counsel would show that Appellant was convicted of sexual assault and was
sentenced to a 14-year sentence.
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IV.
14Volumes of Reporter’s Record:
Cathe Dickson, the Court Reporter for the Trial Court, provided fourteen
volumes of the record.
V.
Counsel’s Work & Schedule:
Counsel would show that he is a solo practitioner without staff and carries
active files involving civil and criminal actions in multiple counties. Further,
Counsel would show that he has been working on the appeal of the murder-life
sentence in Barker v. State, Cause No.: 12-14-00345-CR during the same time as
Counsel was worker on the subject appeal.
VI.
Insufficient Time to Complete Brief:
Counsel would show that based upon the above and forgoing, that he has had
insufficient time within which to complete the Brief.
VII.
Requested Relief:
Counsel requests that the deadline for filing Appellant’s Brief be extended to
May 22, 2015. The subject request for extension is not sought for delay, but only
that justice may be done.
VIII.
Conference:
Counsel would show that he conferred with opposing counsel and this Request
is presented as UNOPPOSED.
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IX.
Word Count Certificate:
Counsel certifies that WORD format character count is 420.
Sten M.
Digitally signed by Sten M.
Langsjoen
DN: cn=Sten M. Langsjoen, o, ou,
Langsjoen
email=sten@langsjoenlaw.com,
c=US
Date: 2015.04.30 11:58:06 -05'00'
_______________________________
STEN M. LANGSJOEN
WHEREFORE, PREMISES CONSIDERED, counsel requests that this
Motion be granted.
Respectfully submitted,
Sten M.
Digitally signed by Sten M.
Langsjoen
DN: cn=Sten M. Langsjoen, o, ou,
Langsjoen
email=sten@langsjoenlaw.com,
c=US
Date: 2015.04.30 11:58:25 -05'00'
_______________________________
STEN M. LANGSJOEN
Attorney for Appellant
P.O. Box 539
Tyler, Texas 75710
Telephone: (903) 531-0171
Telefax: (903) 531-0187
TBA # 11922800
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing was delivered by certified
mail, return receipt requested, and/or by "fax" transmission and/or by hand-delivery
to District Attorney, Cherokee County, Texas, on this 30th day of April, 2015.
Sten M. Digitally signed by Sten M. Langsjoen
DN: cn=Sten M. Langsjoen, o, ou,
Langsjoen
email=sten@langsjoenlaw.com, c=US
Date: 2015.04.30 11:58:48 -05'00'
____________________________
STEN M. LANGSJOEN
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